- 11 - review of the Appeals’ denial. Respondent offered to allow the estate to pay the tax and addition to tax by diverting all of the estate’s partnership income to respondent until the liability is satisfied (i.e., approximately 2 years). The estate refused this offer, insisting that it had a right to make payments over 10 years (i.e., the same contention made in the estate’s request for extension). As respondent pointed out in numerous letters to petitioner, the estate should pay respondent prior to distributing assets to the beneficiaries. Although the estate had a right to only half of the annual payments, the estate’s share of the installments could have paid off the estate’s Federal estate tax liability in approximately 2 years. In addition, in September 1999, Texas law changed, allowing the sale or assignment of the payment stream, almost a year before the Appeals officer issued the determination. To the extent respondent considered installment payments as a collection alternative, there was no abuse of discretion. Contentions we have not addressed are moot, irrelevant, or meritless.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011