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applies. We find that petitioner has failed to establish that
Mehrafsar did not receive notice of the return's extended due
date prior to June 1, 1989. We decline to accept Mehrafsar's
self-serving and contradicted testimony to the contrary. Part 5
of the Form 4768 is entitled "Notice to Applicant--To be
completed by the Internal Revenue Service" and is the portion of
the form where the IRS approved, with qualification, Mehrafsar's
extension request, until March 26, 1989. The approval is dated
November 15, 1988. Moreover, Mehrafsar's address is the only
address listed on the Form 4768, and there is no indication that
the IRS used an address other than that which is on the form when
providing notice of the approval to Mehrafsar.
Petitioner's argument that we should not construe
Mehrafsar's letter, dated August 1, 1989, in the manner discussed
herein is unpersuasive. Accordingly, we conclude that Mehrafsar,
subsequent to becoming aware of the return's extended due date,
did not reasonably rely on the erroneous advice he had received
from Hastings regarding the due date of the estate tax return.
Hence, as the return was filed on November 5, 1989, which is more
than 4 months after June 1, 1989, section 6651(a)(1) imposes an
addition to tax in the amount of 25 percent of the amount of tax
required to be shown on the estate tax return.
Petitioner points to several other factors as evidence for
its contention that the reasonable cause exception provided for
in section 6651(a)(1) applies to the facts of this case. These
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