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of $3,074,4081 and an addition to tax under section 6651(a)(2)2
for failure to pay timely. After concessions, the sole issue for
decision is whether the estate is liable for the addition to tax
under section 6651(a)(2) for failure to pay its Federal estate
tax timely. We hold that it is liable.
FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
by this reference.
Antoinette Hartsell (decedent) was domiciled in Oklahoma
City, Oklahoma, at the time of her death. When the petition was
filed with the Court, Donald C. Renbarger, the executor, resided
in Oklahoma City, Oklahoma.
Decedent died on December 18, 1998, with a gross estate
valued in excess of $13 million. The estate was composed of real
properties, mineral interests, royalty interests, stocks, bonds,
and accounts receivable. The stocks had a fair market value of
$725,190, and the mineral interests had an estimable return value
of $400,000. Over 70 percent of the value of the taxable estate
was attributable to nonliquid assets.
1All monetary amounts have been rounded to the nearest
dollar.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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