In Estate of Liftin, No. 10-589 (Fed. Cl., March 29, 2013), the Court of Federal Claims held that an estate was subject to a late-filing penalty due to its failure to timely file its estate tax return. The decedent died in March 2003, and his son was appointed the Executor of his estate. The decedent’s will provided for outright bequests to a number of people, including his surviving spouse, who was a U.S. resident and a citizen of Bolivia. Following t
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