Estate of Edward P. Roski, Sr., Deceased, Edward P. Roski, Jr., Executor - Page 4

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          findings of fact for this case.  See Estate of Kahn v.                      
          Commissioner, 125 T.C. 227, 228 (2005) (citing Fed. R. Civ. P.              
          52(a) and Lakewood Associates v. Commissioner, T.C. Memo.                   
               Edward P. Roski (decedent) died on October 6, 2000.  He was            
          a resident of Los Angeles, California, at the time of his death.            
          The executor resided in California when the petition was filed.             
               On January 4, 2002, the executor of decedent’s estate filed            
          a timely Form 706, United States Estate (and Generation-Skipping            
          Transfer) Tax Return (the estate tax return), reporting a balance           
          due of $32,778,372.  Attached to the estate tax return was a                
          Notice of Election Under Section 6166 of the Internal Revenue               
          Code, in which the estate elected to defer payment of the balance           
          on the estate tax return.  On June 17, 2003, the estate filed a             
          supplemental Form 706 reporting a liability of $28,901,454.  The            
          estate also amended its section 6166 election to reflect the new            
          balance due.  Pursuant to the election, if the estate were able             
          to obtain the full extension, it would pay the tax due in                   
          installments as late as the 14th anniversary of the normal due              
          date, which would be in 2015.2                                              

               2Sec. 6166(a) allows an estate electing under that section             
          to pay the tax due in installments over a 10-year period after a            
          5-year deferral.                                                            

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