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coexecutors of the estate. The estate had a value in excess of
$4 million at the date of her death.
Form 706, United States Estate Tax Return (estate tax
return), for decedent was due on August 15, 1990, 9 months from
the date of death. The coexecutors failed to file an estate tax
return and to make any payments for estate taxes. On or about
July 26, 1993, respondent filed a substitute for return for the
estate.
On March 7, 1994, petitioner received a summons from
respondent dated February 25, 1994, for testimony and records
regarding the estate tax return. Petitioner did not appear or
respond to the summons. In 1996, petitioner received a call from
respondent informing her that the estate tax return had not been
filed and that the estate taxes had not been paid. Petitioner
responded that the call was the first time that she was made
aware that the estate taxes had not been paid.
On August 2, 1996, respondent issued a notice of deficiency
to the estate. On October 24, 1996, the estate filed a petition
to redetermine the deficiency.
On December 2, 1997, Mary Tom was appointed to serve as
Administratix of the estate. In January 1999, Mary Tom
instituted a suit against William Kabbash and Samuel Kabbash for
alleged waste and mismanagement of the estate. On February 3,
2000, the complaint filed by Mary Tom was amended to add
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