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date of a decedent’s death or within a longer period as extended
by the Secretary. Edna died on July 3, 1998, and the estate tax
return was filed on September 5, 1999. The estate did not
request an extension to file the return, and none was granted.
Because the value of Edna’s gross estate exceeds the applicable
exclusion amount under section 2010 in effect for 1998, $625,000,
her estate was required to file a return within 9 months of her
death. Sec. 6018(a)(1). It did not. The estate does not argue
that it had reasonable cause for its failure to file a timely
return or that the addition to tax under section 6651(a)(1) is
not appropriate. Therefore, we find that the estate is liable
for the addition to tax under section 6651(a)(1) on the estate
taxes due.
To reflect the foregoing, and concessions by the parties,
Decision will be entered
under Rule 155.
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