Estate of Gertrude Zlotowski, Deceased, Gunther Grewe, Ancillary Administrator, C.T.A. - Page 13

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               C.  Conclusion                                                         
               Petitioner has failed to show that, on account of reasonable           
          cause and not due to willful neglect, petitioner is excepted from           
          liability for the section 6651(a)(1) addition to tax.                       
          IV.  Conclusion                                                             
               Petitioner is liable for an addition to tax pursuant to                
          section 6651(a)(1) for failure to file timely the Form 706.                 

                                                  Decision will be entered            
                                             under Rule 155.                          






















               2(...continued)                                                        
          available and later filing an amended return.  See Estate of                
          Vriniotis v. Commissioner, 79 T.C. 298, 311 (1982).                         





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