Estate of Margaret Landers, Deceased, Dale Seltzer, Co-Administrator - Page 6

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          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 under            






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