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Moreover, the regulations provide that, even if the
information available is not sufficient to permit preparation of
a complete estate tax return as of an extended due date for
filing such a return, a return that is as complete as possible
must be filed by that due date. Sec. 20.6081-1(c), Estate Tax
Regs; see also sec. 20.6018-2, Estate Tax Regs. Additionally,
the regulations permit the filing of supplemental information.
Sec. 20.6081-1(c), Estate Tax Regs. Our cases are to the same
effect. See Estate of Cavenaugh v. Commissioner, supra at 426;
Bank of the West v. Commissioner, 93 T.C. 462, 471 (1989); Estate
of Vriniotis v. Commissioner, 79 T.C. 298, 311 (1982); Estate of
Duttenhofer v. Commissioner, 49 T.C. 200, 206-207 (1967), affd.
410 F.2d 302 (6th cir. 1969). The uncertainty upon which
petitioner relies would not have prevented the filing of a
reasonably accurate return within the time allowed.
Consequently, we reject petitioner's contention that the
uncertainty surrounding the identification of decedent's assets
constitutes reasonable cause for the failure to file petitioner's
estate tax return timely.
We next consider petitioner's contention that reasonable
cause for failure to file timely is shown by Mr. Constantino's
purported reliance on Mr. Belotz' advice or lack of advice. We
note that reliance on erroneous advice may furnish reasonable
cause for a failure to file timely in certain limited
circumstances. United States v. Boyle, supra at 250; Estate of
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