- 22 -
Based on the record as a whole, we conclude that petitioner
has failed to establish that the failure to file timely was due
to reasonable cause.8
To reflect the foregoing, concessions, and the claim of
additional expenses,
Decision will be entered
under Rule 155.
8 We note that Mr. Constantino was an attorney who was
appointed by the superior court to administer the estate. While
one court has indicated that a professional executor should be
held to a stricter standard than a layperson for purposes of sec.
6651(a), Estate of Cox v. United States, 637 F. Supp. 1112, 1115
(S.D. Fla. 1986), we need not apply such a standard to reach our
result herein. Even using the standards applicable to
laypersons, we find that petitioner has failed to demonstrate
that the failure to file timely was due to reasonable cause.
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