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decision is whether petitioner is liable for the previously
mentioned addition to tax for late filing pursuant to section
6651(a)(1).1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein. At the time the petition was filed, the special
administrator's principal place of business was in Pasadena,
California. Houshang Mehrafsar (decedent) died on December 26,
1987. He was survived by his only child, Marlon Mehrafsar
(Mehrafsar). At the time of decedent's death, Mehrafsar was 21
years old and had earned an associate's degree. Mehrafsar was
appointed the special administrator of decedent's estate, and he
was serving in such capacity when the estate's Federal estate tax
return was filed. Bank of America, NT, is now the special
administrator of decedent's estate.
During his lifetime, decedent had a continuing association
with his business adviser and his attorney. Leonard Warren
(Warren), decedent's business adviser, was a professional real
estate broker and appraiser. In such capacity, Warren served as
an adviser to decedent's real estate investment activities.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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