Estate of Irving Nemerov, Deceased, Bernice Midgorden, Personal Representative - Page 8

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                    date prescribed therefor (determined with                         
                    regard to any extension of time for filing),                      
                    unless it is shown that such failure is due                       
                    to reasonable cause and not due to willful                        
                    neglect, there shall be added to the amount                       
                    required to be shown as tax on such return                        
                    5 percent of the amount of such tax if the                        
                    failure is for not more than 1 month, with an                     
                    additional 5 percent for each additional                          
                    month or fraction thereof during which such                       
                    failure continues, not exceeding 25 percent                       
                    in the aggregate;                                                 
                         (2) to pay the amount shown as tax on                        
                    any return specified in paragraph (1) on or                       
                    before the date prescribed for payment of                         
                    such tax (determined with regard to any                           
                    extension of time for payment), unless it is                      
                    shown that such failure is due to reasonable                      
                    cause and not due to willful neglect, there                       
                    shall be added to the amount shown as tax on                      
                    such return 0.5 percent of the amount of such                     
                    tax if the failure is for not more than 1                         
                    month, with an additional 0.5 percent for                         
                    each additional month or fraction thereof                         
                    during which such failure continues, not                          
                    exceeding 25 percent in the aggregate; * * *                      
                    (b) Penalty Imposed on Net Amount Due.--For                       
               purposes of--                                                          
                         (1) subsection (a)(1), the amount of tax                     
                    required to be shown on the return shall be                       
                    reduced by the amount of any part of the tax                      
                    which is paid on or before the date                               
                    prescribed for payment of the tax and by the                      
                    amount of any credit against the tax which                        
                    may be claimed on the return,                                     
                         (2) subsection (a)(2), the amount of tax                     
                    shown on the return shall, for purposes of                        
                    computing the addition for any month, be                          
                    reduced by the amount of any part of the tax                      
                    which is paid on or before the beginning of                       
                    such month and by the amount of any credit                        
                    against the tax which may be claimed on the                       
                    return, * * *                                                     





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