- 41 -
Commissioner, 21 T.C. 1012, 1019 (1954), affd. 225 F.2d 629 (10th
Cir. 1955).
Accordingly, we hold on this record that petitioner has not
carried its burden of proof that the delinquent filing of the
estate tax return was due to reasonable cause and not to willful
neglect. Therefore, petitioner is liable for the addition to tax
under section 6651(a).
To reflect the foregoing,
Decision will be entered under
Rule 155.
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