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During July 1991, Mr. Belotz began preparing petitioner's
estate tax return. By letter dated July 5, 1991, Mr. Belotz
notified Mr. Constantino that Mr. Belotz required certain
information in order to prepare various tax returns, such as
details of funeral expenses, and attached a blank Form 706,
United States Estate (and Generation-Skipping Transfer) Tax
Return, with the items for which information was required circled
in red. Mr. Constantino returned the estate tax return form with
a letter dated July 24, 1991, which stated that he was working on
the inventory. A handwritten notation on the copy of the July 5,
1991, letter in the record states as follows: "Mailed a blank
copy of Form 706, circled items in red for Constantino to answer
or submit data! He just signed the blank form, entered his S.S #
and mailed it all back to my office".
During August 1991, Messrs. Constantino, Blum, and Belotz
discussed applying for a second and further extension of the due
date of the estate tax return because uncertainty still existed
as to whether all of decedent's assets had been identified. When
Messrs. Constantino and Blum asked Mr. Belotz about this, Mr.
Belotz replied that, in all his experience, which included
preparing over 50 Federal estate tax returns, he had never before
had occasion to request a second extension of a due date.
Nonetheless, Mr. Belotz thought that there was good cause for
requesting a second extension given the problems with the estate.
Mr. Belotz, however, found no form for applying for such an
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