- 10 -
By the same token, we also reject petitioner's illiquidity
argument because it is wholly without merit. Moreover,
petitioner's argument regarding the estate's inability to obtain
property appraisal values is equally without merit.
After carefully examining the facts and circumstances of
this case, and after giving appropriate weight to the testimony
of each witness and the exhibits contained in the record, we
conclude that petitioner has failed to establish that the
delinquent filing of the estate tax return was due to reasonable
cause. Accordingly, respondent's determination is sustained.
To reflect the foregoing,
Decision will be
entered under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011