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factors include Mehrafsar's youth and inexperience, the
complexity and illiquidity of the estate, the existence of
multiple wills, an inability to obtain property appraisal values,
and the need to locate estate assets. None of these factors,
whether viewed individually or collectively, convince us that the
reasonable cause exception precludes application of the late
filing penalty in the instant case. Petitioner cites little
authority for its argument pertaining to most of these factors.
The authority petitioner does cite is inapposite.
We do not find that Mehrafsar's age or inexperience in tax
matters presents a valid defense to the addition to tax. He was
over 21 years old at the time of decedent's death. Furthermore,
Mehrafsar did not undertake his duties as special administrator
on his own, but with the assistance of several professional
advisers.
Similarly, we do not find that the complexity of decedent's
estate, whether due to pending will contests or the need to
locate additional assets, prevented Mehrafsar from filing timely
the estate tax return. The law requires that a return be filed
timely, based upon "the information then available". Estate of
Duttenhofer v. Commissioner, 49 T.C. at 206-207; Estate of
Vriniotis v. Commissioner, 79 T.C. 298, 311 (1982). If and when
the pending complexities were resolved in a manner that affected
estate tax liability, petitioner could have filed an amended
return. See Estate of Duttenhofer v. Commissioner, supra.
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