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section 61611 extension request was an abuse of discretion; (2)
respondent’s denial of the estate’s request for abatement of a
section 6651(a)(2) addition to tax for failure to pay was an
abuse of discretion; and (3) respondent’s determination
sustaining the proposed collection action was an abuse of
discretion.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. When the petition was filed, petitioner’s
representative, Jimmy Mack Doster, Independent Executor
(executor), resided in Sulphur Springs, Texas. At the time of
his death, Donny David Doster was domiciled in Texas.
On February 5, 1997, Donny Doster and his wife, Judy Doster,
won a $35.3 million Texas lottery jackpot (Lotto), payable in 20
annual installments of $1,768,000. On March 15, 1997, the
Dosters formed Texas East-West Limited Partnership to collect and
invest the Lotto proceeds. Mr. and Mrs. Doster each received a
2-percent general partnership interest and a 48-percent limited
partnership interest.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011