- 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 NextLast modified: May 25, 2011