Portability Election Deadline Extended

By Julia Thomas | February 20, 2012

On February 17, 2012, the IRS issued Notice 2012-21, which allows certain estates of married individuals who died during the first six months of 2011 to extend the time to make the portability election. Code section 2010(c) was amended in 2010 to allow the estate of a decedent who dies after 2010 and who is…

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Baccei v. U.S.: Taxpayer Cannot Avoid Late Payment Penalty

By Julia Thomas | March 15, 2011

In Baccei v. U.S. (9th Cir. Feb 16, 2011), the estate’s accountant failed to properly complete Form 4768 requesting an extension of time to pay estate tax and the IRS assessed a late payment penalty. The estate paid the penalty and sued for a refund. The estate lost in District Court and appealed to the…

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