-3-
estate tax return and (2) a $130,028.16 addition to tax under
section 6651(a)(2). The estate paid the $470,098.56 (but not the
related interest) on May 4, 2006.
Following a trial of these cases, we decide whether either
the late filing of the estate tax return or the late payment of
the related tax was due to reasonable cause. We hold that
neither was.
FINDINGS OF FACT
1. Preface
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Margaret Landers (decedent) died on January 21, 2000. The
coadministrators of the estate were Dale Seltzer (Seltzer) and
Mark Gershon (Gershon). The coadministrators each vowed to
“perform the duties of personal representative according to law”.
Gershon died on December 13, 2003, and Seltzer is now the
estate’s sole administrator. Seltzer resided in Los Angeles,
California, when the petitions were filed in these cases.
2. Robert Landers
Robert Landers was decedent’s husband, and he died on
January 29, 1993. In 1984, Robert Landers and decedent
(collectively, the Landerses) established a revocable trust
(trust). The trust held most of decedent’s property. Seltzer
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