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circumstances. Estate of Hartsell v. Commissioner, T.C. Memo.
2004-211; Merriam v. Commissioner, supra.
The regulations and other administrative guidance provided
by respondent concerning reasonable cause for a failure to pay
under section 6651(a)(2) are generally directed at the
circumstances surrounding a taxpayer's inability to pay when due,
and not defalcations in remitting payment, as occurred in the
instant case. Reasonable cause in the case of failures in
mailing or delivery are addressed in connection with failures to
file under section 6651(a)(1), however, and present persuasive
analogues, in our view. Respondent has advised his employees
that reasonable cause for a failure to file timely generally
exists where a return has been timely mailed but returned for
insufficient postage, or sent to the wrong district. 2 Audit,
Internal Revenue Manual (CCH), sec. 4562.2 at 14,356 (Feb. 25,
1987); see also United States v. Boyle, supra at 243 n.1; McMahan
v. Commissioner, 114 F.3d 366, 369 (2d Cir. 1997), affg. T.C.
Memo. 1995-547. However, an important factor bearing upon
reasonable cause is the expeditiousness with which a taxpayer
rectifies a mistake, once discovered. See Internal Revenue
Manual (IRM) sec. 20.1.1.3.1.2 (2) (Aug. 20, 1998) (assessment of
ordinary business care and prudence requires consideration of
length of time between the event cited as a reason for
noncompliance and subsequent compliance); IRM sec. 20.1.1.3.1.2.3
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