Estate of Donny David Doster - Page 3




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               On July 30, 1997, Mr. Doster died.  On that date, Mr.                  
          Doster’s interest in the partnership, which passed to his estate,           
          consisted primarily of the right to receive half of each of the             
          19 remaining Lotto installments.  Texas law prohibited the sale             
          or assignment of such installments.                                         
          I.   Request for Extension of Time To Pay Estate Taxes                      
               On April 29, 1998, the estate filed Form 706, United States            
          Estate Tax Return, reporting estate tax liability of $1,730,845.            
          The Form 706 stated that the gross estate’s value was $5,110,517,           
          which included Mr. Doster’s share of the partnership, valued at             
          $4,428,616.  The Form 706 also stated that the estate was                   
          entitled to deductions for funeral expenses, debts of decedent,             
          and interests passing to the surviving spouse of $55,019, $4,507,           
          and $243,850, respectively.                                                 
               Accompanying the return was a payment of $346,169 and Form             
          4768, Application for Extension of Time to File a Return and/or             
          Pay U.S. Estate Taxes (extension request), in which the estate              
          sought permission to pay the $1,419,430 balance over 10 years.              
          The estate contended it had reasonable cause for an extension               
          because it could not “borrow * * * except at a rate of interest             
          higher than that generally available”, or sell its interest in              
          the Lotto installments.  The estate further contended that                  
          liquidation of the partnership interest would not yield a                   





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