- 18 - point at which we determine whether reasonable cause existed. Accordingly, we do not find the ongoing litigation imposed a unique or an undue hardship on the estate. VI. The Estate’s Attempts To Obtain Alternative Sources of Financing Next we address respondent’s arguments that the estate failed to pursue other sources of potential financing or income to pay its Federal estate tax. The estate consists principally of non-income-producing property. Consequently, Mr. Renbarger claimed the few liquid assets the estate owned and the income they produced were needed to maintain the estate. Mr. Renbarger therefore claims that the estate could raise money only by advertising and selling its real properties. Respondent counters that the estate failed to make reasonable efforts to obtain alternative financing. Respondent first claims Mr. Renbarger failed to exercise ordinary business care and prudence in forgiving two of the estate’s accounts receivable and not enforcing collection of interest payments on one. Before her death, decedent had lent $111,000 to Mr. Renbarger and $760,000 to his son, Randy Renbarger.9 Randy Renbarger made monthly interest payments of approximately $4,000 to decedent in connection with his loan but instantly stopped making monthly interest payments at decedent’s 9Decedent financed her $760,000 loan to Randy Renbarger by obtaining a mortgage on certain property she owned.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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