Estate of Wayne-Chi Young, Deceased, Tsai-Hsiu Hsu Yang, Executrix - Page 41

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          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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