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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.
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