- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011