Estate of Houshang Mehrafsar, Deceased, Bank of America, NT & SA, Special Administrator - Page 10

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               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.                  
























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