- 9 - tax. Respondent specifically argues that Mr. Renbarger failed to seriously pursue financing, did not advertise a sufficient amount of real estate to pay the Federal estate tax, preferred State estate tax payments over Federal estate tax payments, and failed to collect outstanding accounts receivable. For the reasons set forth, the Court agrees with respondent that the estate has failed to show reasonable cause and no willful neglect for its failure to pay timely and is therefore liable for the addition to tax under section 6651(a)(2). II. The Estate’s Payment History The estate paid only $100,000 to respondent by the payment due date. The estate made two additional payments after the payment due date and before trial. First, the estate paid respondent $1.2 million, its only significant payment, more than 2 years after the payment due date. Second, the estate paid respondent $168,682 nearly 3 years after the payment due date and just 2 days before trial. Moreover, the estate’s $1.2 million payment was not even attributable to efforts it made to sell property. Rather, the sale resulted from the buyer’s exercise of an option to purchase that decedent had granted before her death. Further, the proceeds from the sale were deposited in escrow for respondent on May 10, 2000, and yet the estate waited an additional 2 years before it released the funds to respondent.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