- 11 - constitutes the estate’s central argument that it exercised ordinary business care and prudence and could not, without undue hardship, sell sufficient property to pay its Federal estate tax by the payment due date. The plan essentially involved selecting five properties to sell, advertising and marketing those properties, and, once they were sold, selecting additional properties to sell. Mr. Renbarger chose to sell a mere five properties from an estate composed of more than 60 properties. He advertised the properties by placing a single “for sale” sign on each with a phone number. Mr. Renbarger waited, no bids were received, and the deadline, extended twice, passed without payment. One person contacted the estate regarding a property but expressed no interest upon hearing the asking price. Mr. Renbarger did not enlist the assistance of a professional real estate broker and instead relied on his own expertise and that of a small team, which included his two sons. Mr. Renbarger attributes his lack of success in selling the estate’s five properties to macroeconomic events including a slowing economy, the national recession beginning March 2001, the collapse of Enron, the State and national declines in real income, the evaporation of stock investor wealth, and even the uncertainties of war in Afghanistan and Iraq and the events of September 11, 2001. We are unconvinced by Mr. Renbarger’s argument, particularly considering that most of the eventsPage: 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