- 68 - e. Other Considerations Each coexecutor is college educated, and both have extensive work experience. Each knows about her obligation to file valid Federal tax returns. f. Conclusion After our detailed review of the facts and circumstances of this case, in conjunction with our analysis of the factors mentioned above, we conclude that respondent has clearly and convincingly proven that the coexecutors filed the decedent's estate tax return intending to conceal, mislead, or otherwise prevent the collection of tax. We also conclude that section 6664(c) does not insulate the estate from this penalty; we find no reasonable cause for the underpayment, nor that the estate acted in good faith with respect to the underpayment. We sustain respondent's determination of fraud. We have considered all arguments made by the parties, and, to the extent not addressed above, find them to be irrelevant or without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68
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