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On April 5, 1999, decedent’s Last Will and Testament was
admitted to probate by the District Court for Oklahoma County,
Oklahoma. Pursuant to the will, decedent devised her entire
estate to her friend Donald C. Renbarger (Mr. Renbarger) and
expressly disinherited her half-sister and step-sister. Decedent
also designated Mr. Renbarger “personal representative” of the
estate.
The original due date for the Federal estate tax to be paid
was September 20, 1999. Mr. Renbarger submitted a timely request
for an extension of time to pay the Federal estate tax under
section 6161 and a partial payment of $100,000 toward a total
Federal estate tax liability of $4,267,373. Respondent granted
the first request for an extension of time to pay through March
16, 2000. Mr. Renbarger submitted a second timely request for an
extension of time to pay, which respondent granted through March
18, 2001 (payment due date).
Mr. Renbarger submitted a third request for an extension of
time to pay on March 9, 2001. Respondent mailed Mr. Renbarger a
request to substantiate reasonable cause for further extending
the payment due date. Because Mr. Renbarger failed to
substantiate reasonable cause, respondent denied the estate’s
third request for an extension of time to pay. The final payment
due date was therefore March 18, 2001.
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Last modified: May 25, 2011