- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011