-3- estate tax return and (2) a $130,028.16 addition to tax under section 6651(a)(2). The estate paid the $470,098.56 (but not the related interest) on May 4, 2006. Following a trial of these cases, we decide whether either the late filing of the estate tax return or the late payment of the related tax was due to reasonable cause. We hold that neither was. FINDINGS OF FACT 1. Preface Some facts were stipulated. We incorporate herein by this reference the parties’ stipulation of facts and the exhibits submitted therewith. We find the stipulated facts accordingly. Margaret Landers (decedent) died on January 21, 2000. The coadministrators of the estate were Dale Seltzer (Seltzer) and Mark Gershon (Gershon). The coadministrators each vowed to “perform the duties of personal representative according to law”. Gershon died on December 13, 2003, and Seltzer is now the estate’s sole administrator. Seltzer resided in Los Angeles, California, when the petitions were filed in these cases. 2. Robert Landers Robert Landers was decedent’s husband, and he died on January 29, 1993. In 1984, Robert Landers and decedent (collectively, the Landerses) established a revocable trust (trust). The trust held most of decedent’s property. SeltzerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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