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6. Whether petitioner, pursuant to section 6651(a)(1), is
liable for an addition to tax for failing to file its estate tax
return in a timely manner. We hold that petitioner is liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time of her death, on January 28, 1989, Bonnie Harden resided
in South Lake Tahoe, California. At the time the petition was
filed, the executor resided in Los Angeles, California.
Earl and Bonnie Harden were married and lived together in
South Lake Tahoe, California, until Earl's death in February of
1985. Previously Earl and Bonnie had both retired from the
business of selling and installing countertops. Although Earl
had severe physical limitations (i.e., he was confined to a
wheelchair) as a result of a fall in 1981, he continued to make
decisions independently. Earl and Bonnie had one adult son,
Rory.
In 1981, Earl and Bonnie met David Kotler, and they quickly
became close friends. David was an accountant. He graduated in
1976 from Long Island University, C.W. Post School of
Professional Accountancy, in New York. After graduating, he
moved to California. During the course of his career, he was
employed by accounting firms and defense contractors.
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