- 22 -
and to pay timely the estate tax shown to be due was due to
reasonable cause and not to willful neglect.10 Thus, the Court
holds that the estate is liable for the additions to tax under
section 6651(a)(1) and (2) which were previously assessed and
paid and the amount determined by respondent in the notice of
deficiency. Respondent's determination in the notice of
deficiency is sustained, and the estate is not entitled to a
refund of amounts previously assessed and paid.
Decision will be entered
for respondent.
10 To the extent not explicitly stated in this opinion,
the Court's application of the relevant law to the facts in this
case applies equally to the addition to tax under sec. 6651(a)(2)
and to the addition to tax under sec. 6651(a)(1).
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Last modified: May 25, 2011