Estate of Joseph G. Maltaman, Deceased, Paul J. Constantino, Special Administrator - Page 13

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               Moreover, the regulations provide that, even if the                    
          information available is not sufficient to permit preparation of            
          a complete estate tax return as of an extended due date for                 
          filing such a return, a return that is as complete as possible              
          must be filed by that due date.  Sec. 20.6081-1(c), Estate Tax              
          Regs; see also sec. 20.6018-2, Estate Tax Regs.  Additionally,              
          the regulations permit the filing of supplemental information.              
          Sec. 20.6081-1(c), Estate Tax Regs.  Our cases are to the same              
          effect.  See Estate of Cavenaugh v. Commissioner, supra at 426;             
          Bank of the West v. Commissioner, 93 T.C. 462, 471 (1989); Estate           
          of Vriniotis v. Commissioner, 79 T.C. 298, 311 (1982); Estate of            
          Duttenhofer v. Commissioner, 49 T.C. 200, 206-207 (1967), affd.             
          410 F.2d 302 (6th cir. 1969).  The uncertainty upon which                   
          petitioner relies would not have prevented the filing of a                  
          reasonably accurate return within the time allowed.                         
          Consequently, we reject petitioner's contention that the                    
          uncertainty surrounding the identification of decedent's assets             
          constitutes reasonable cause for the failure to file petitioner's           
          estate tax return timely.                                                   
               We next consider petitioner's contention that reasonable               
          cause for failure to file timely is shown by Mr. Constantino's              
          purported reliance on Mr. Belotz' advice or lack of advice.  We             
          note that reliance on erroneous advice may furnish reasonable               
          cause for a failure to file timely in certain limited                       
          circumstances.  United States v. Boyle, supra at 250; Estate of             




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