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respondent on May 10, 2000. Over 2 years later and after the
payment due date, Mr. Renbarger paid $1.2 million of that amount
to respondent. The remainder was used to pay State estate taxes.
Mr. Renbarger submitted one additional payment of $168,682 to
respondent 2 days before trial.
Since decedent’s death, the estate has paid State estate
taxes to four States. By the time of trial, the estate had paid
$1,433,288 to the State of Oklahoma, $85,704 to the State of
Colorado, $18,090 to the State of Kansas, and $12,589 to the
State of Texas. In total, the estate has paid State estate and
Federal estate taxes of $3,209,052, including interest.
Before her death, decedent had lent $760,000 to Mr.
Renbarger’s son and $111,000 to Mr. Renbarger. Mr. Renbarger’s
son ceased making interest payments to decedent of approximately
$4,000 per month after she died. As the executor, Mr. Renbarger
later forgave the loan to himself and had not, by the trial date,
enforced collection of the principal or interest on the loan to
his son.
The estate was a party to three cases involving its
properties on the payment due date. Three additional cases
commenced after the payment due date.
Mr. Renbarger directed two informal inquiries into the
possibility of using one of the estate’s properties as collateral
for a loan in order to pay its Federal estate tax. In both
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