Estate of Margaret Landers, Deceased, Dale Seltzer, Co-Administrator - Page 3

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          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.  Seltzer              






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