-6- section 6651(a)(1) and (2) of $340,070.40 and $130,028.16, respectively, and related interest of $192,962.20. As of the date of decedent’s death, the estate held assets with an aggregate value in excess of $9 million. After the estate tax return was filed, the estate paid the following amounts toward its tax liability: $500,000 on April 29, 2002, $500,000 on May 13, 2002, and $104,386.20 on June 11, 2002. The coadministrators obtained the funds to make these three payments by refinancing some of the estate’s real property. These three payments paid the balance of the estate tax shown as due on the return, plus the assessed interest. Seltzer knew there was a deadline to file the estate tax return and that an extension of time had been obtained for filing that return. Seltzer did not ascertain the extended due date for the return or attempt to ascertain the extended due date from anyone other than Gershon but was content to rely on Gershon to file the estate tax return timely. Seltzer’s habit was to satisfy obligations immediately, and when the estate tax return was being prepared, Seltzer made sure that the bills of DPM and GlenLee were paid. Seltzer was in good health throughout the time that the estate tax return was under preparation. 6. The Audit of The Estate Tax Return Respondent audited the estate tax return and proposed a deficiency of $53,790 and an addition to tax of $13,447.46 underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011