Mary A. Saigh, a.k.a. Mary Saigh, Transferee - Page 3

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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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