- 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Last modified: May 25, 2011