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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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