- 27 -
15, 1980. Secs. 6019, 6075(b). Petitioner has stipulated that
the co-personal representatives of Birnie's estate filed a
Federal gift tax return for the quarter ended September 30, 1980,
on November 7, 1991. Petitioner has made no argument with
respect to the section 6651(a)(1) addition to tax, except by
implication of its argument that no gift was made. We rejected
that argument supra, and petitioner has not proven that its
failure to file timely was due to reasonable cause. Accordingly,
we sustain respondent's determination of the applicable addition
to tax under section 6651(a)(1).
To reflect the foregoing,
Appropriate orders will
be issued, and decisions will
be entered under Rule 155.
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