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occurred on or after the payment due date. For example, the
recession beginning in March 2001, the events of September 11,
2001, and the collapse of Enron in December 2001 all occurred on
or after March 18, 2001, the estate’s payment due date.
Adverse economic conditions do not necessarily constitute
reasonable cause. See Wolfe v. United States, 612 F. Supp. 605,
607-608 (D. Mont. 1985), affd. on other grounds 798 F.2d 1241
(9th Cir. 1986), amended on denial of rehearing 806 F.2d 1410
(9th Cir. 1986). In Wolfe, the court considered whether
financial difficulties due in part to the Arab oil embargo
constituted reasonable cause for failing to pay by the payment
due date. Id. The court stated that almost every nonwillful
failure to pay taxes is the result of financial difficulties, and
to allow taxpayers to postpone paying taxes until economic
conditions improve would severely restrict the Internal Revenue
Service’s ability to raise revenue. Id.
Likewise, the estate has failed to adequately demonstrate
how these economic events causally affected its ability to sell
properties. Rather, we attribute the lack of interest in the
estate’s properties to its arbitrary prices, negligible marketing
efforts, too few properties advertised, a desire to save paying
third parties other than Mr. Renbarger and his sons, and,
overall, a desire to sell at a profit rather than at current
market prices. See sec. 20.6161-1(a)(2)(ii), Estate Tax Regs.
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