On November 15, 2017, Robert died in a hospital in Texas just two and half years after being diagnosed with early onset Alzheimer's disease. The exact cause of death of death was aspiration pneumonia and the last few months of Robert's life he was unable to recognize lifelong friends or recall the extent of his assets. In fact, there is some evidence that Robert had lost the ability to reason at a high level for up to six months before he died. Robert had $42,000,000 worth of assets at the time of his death with half of the value being minority interests in various privately held businesses that were retaining earnings and not issuing dividends to the shareholders. Page 2 of 4 Robert was a domiciliary of Louisiana at the time of his death. Robert's longtime close friend, Tommy, probates the properly executed Last Will and Testament of Robert, which was in Tommy's possession and named Tommy as executor of Robert's estate. The will was dated as of February 16, 2013. The will left the entirety of Robert's estate, via a trust, to Robert's only two legitimate children (Jack and Jill, who are both 35 years old) from his first marriage. By October 1, 2019 nothing had been distributed and Robert's estate was inundated with problems: Issue A) Robert's divorced wife Janice (the mother of Jack and Jill) has made a formal claim against the Estate of Robert because starting in December of 2018 Tommy stopped the monthly autodraft out of Robert's bank account that was paying Robert's $20,000 monthly alimony obligation to Janice that was issued by the state of Colorado and purported to be owed by Robert for Janice's life. Janice demands the estate fund an annuity for her expected lifetime pursuant to the Single Life Expectancy Table and make all back-payments from December of 2018 through the present day. Tommy's position is Janice can go "pound sand". Issue B) Robert's widow Sarah (who he was married to for nineteen years before his death but estranged from for the final ten years of his life) brought a claim alleging that the marriage contract she entered into with Robert before their nuptials was invalid because she was on cocaine and opioids at the time she executed the marriage contract and she therefore lacked contractual capacity. She claims her interest in the community property is worth $15,000,000 and claims a 'marital portion' in the alternative. Issue C) Robert's girlfriend Debbie, who lived in Texas, alleges that Robert was her common law husband because he would periodically stay at her house for many months at a time over the ten-year period they were a couple and he would publicly hold her out as his wife when they would go to the bar by her house. She brings a claim seeking to enforce whatever rights she may be found to have as a common law wife. Issue D) Robert's nurse Peter has a $7,500,000 promissory note that purports to be "for value received" and "payable on demand" and issued from Robert (under private act with no witnesses or notary) to Peter just one month before Robert died. Peter cannot explain to anyone's reasonable satisfaction why Robert gave him this note but he has filed a claim against the estate to collect on the note. Issue E) Robert's alleged 22-year-old illegitimate son, David, who is a citizen of Oregon, intervenes into the Louisiana action and alleges he is a forced heir under Louisiana law and demands his forced portion. Robert never acknowledged David or even knew David existed before his death, but '23 and me' tests have concluded that David (who was an orphan and never knew his mother or father) is the biological son of Robert and David now demands more formal testing be ordered by the court and that he be treated the same as Jack and Jill. Issue F) Robert's pastor, Joe, says that six months before Robert's death Robert made a verbal promise in front of the entire congregation that on his death he was going to leave a legacy of $5,000,000 to the church. Tommy was a member of this church and was present when Robert made this pledge, so he knows for certain that Joe is telling the truth. Page 3 of 4 Issue G) Robert's sister, Dana, says that five months before Robert's death Robert promised he was going to leave her $1,000,000 in his estate. She wants to enforce that promise against the estate even though the Last Will and Testament made no mention of her at all and she has sent a demand letter to Tommy but has not intervened in the estate. Issue H) Robert's off the records sports betting agent, Arturo, brings a claim that Robert owed him $250,000 in unpaid debts for bets Robert lost. Sports betting was illegal at the time Arturo claims Robert incurred the debt, but Arturo has several witnesses who can verify the bets were made by Robert. Issue I) As of October 1, 2019, Tommy has not remitted any estimated tax payment or filed a Form 706 estate tax return or sought any formal extension from the IRS beyond sending them a series of letters outlining his problems and stating that the small businesses that Robert owned an interest in will not cooperate with his estate appraisers and that Tommy can't get any liquidity to pay any estate taxes anyway because the value of the estate is tied up in non-liquid businesses that are not making any distributions. Tommy further promises in his letters that he will get an estate tax identification number soon. The Service has not responded to any of Tommy's letters and has yet to reach out to Tommy in any way whatsoever. Tommy did call the "IRS Help Line" and after hearing all of this the IRS help line representative (Jonathan) told Tommy "hey dude, sounds like you got some problems, hahaha, don't worry about it, hahaha, you just settle up those problems with the Louisiana state courts and you can file that Form 706 with uslater, hahaha, can't wait to hear how this all turns out, hahaha". Tommy clandestinely recorded the conversation. Issue J) Tommy has learned that Robert did not file any state or federal tax returns at all for 2016. Tommy knowsthat Robert was a bit of lush and that Robert frequently told people whatever they wanted to hear. Despite that, and the pledge made to Joe, Tommy believes fully that Robert intended to leave everything he had to Jack and Jill and Tommy desires to see to it that this result happens. Tommy also wants to be paid for his time serving as an executor of the estate. Robert made no provision for how Tommy was to be paid and the will did not say Tommy should not be paid; it was simply silent on executor compensation. With the above fact pattern in mind, Tommy has come to your law firm seeking aid and advice on October 1, 2019. You are a first-year attorney (you were a practicing CPA before going to law school and your CPA license is also current) and the managing partner in your firm has come to you and said you are fully in charge of this case and told you to go "sign Tommy up and work the file".