- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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