Estate of Antoinette Hartsell, Deceased, Donald C. Renbarger, Personal Representative - Page 9

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          tax.  Respondent specifically argues that Mr. Renbarger failed to           
          seriously pursue financing, did not advertise a sufficient amount           
          of real estate to pay the Federal estate tax, preferred State               
          estate tax payments over Federal estate tax payments, and failed            
          to collect outstanding accounts receivable.  For the reasons set            
          forth, the Court agrees with respondent that the estate has                 
          failed to show reasonable cause and no willful neglect for its              
          failure to pay timely and is therefore liable for the addition to           
          tax under section 6651(a)(2).                                               
          II.  The Estate’s Payment History                                           
               The estate paid only $100,000 to respondent by the payment             
          due date.  The estate made two additional payments after the                
          payment due date and before trial.  First, the estate paid                  
          respondent $1.2 million, its only significant payment, more than            
          2 years after the payment due date.  Second, the estate paid                
          respondent $168,682 nearly 3 years after the payment due date and           
          just 2 days before trial.                                                   
               Moreover, the estate’s $1.2 million payment was not even               
          attributable to efforts it made to sell property.  Rather, the              
          sale resulted from the buyer’s exercise of an option to purchase            
          that decedent had granted before her death.  Further, the                   
          proceeds from the sale were deposited in escrow for respondent on           
          May 10, 2000, and yet the estate waited an additional 2 years               
          before it released the funds to respondent.                                 






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