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education, apparent competency, and our longstanding and mutually
productive relationship."
Petitioner contends that respondent did not present any
evidence to contradict that she reasonably relied upon her
accountant's advice. However, as we have noted, the burden of
proof is on petitioner to establish (1) that the failure did not
result from willful neglect and (2) that the failure was due to
reasonable cause. In light of this burden, we note that
petitioner did not call the accountant to testify to corroborate
Yang's testimony. See Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th
Cir. 1947). In light of Yang's uncorroborated testimony, we
consider the following facts to evaluate whether petitioner has
met the burden of proving that Yang reasonably relied upon the
accountant's advice.
The executrix Yang admitted that she knew that decedent's
assets totaled more than $1,200,000 at his death. This clearly
meets the filing threshold as required by law. Petitioner
contends that the executrix relied upon the accountant's
statement that "the Estate Tax Return would probably not be
required."
To support its position, petitioner relies on United States
v. Boyle, supra at 250. In Boyle, the executor argued that the
failure to file the return was due to reasonable cause, reliance
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