Estate of Antoinette Hartsell, Deceased, Donald C. Renbarger, Personal Representative - Page 18

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          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.                         




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