Estate of Antoinette Hartsell, Deceased, Donald C. Renbarger, Personal Representative - Page 2

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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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