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
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Last modified: November 10, 2007