Estate of Nancy Sblendorio, Deceased, Michael F. Poppo, Executor - Page 3

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               In a letter dated August 27, 2003, Mr. Poppo requested an              
          abatement of the additions to tax for reasonable cause, which was           
          received for review by the IRS Service Center in Cincinnati,                
          Ohio.  Mr. Poppo explained that at the time the estate’s income             
          tax return was originally due, October 15, 2002, he did not have            
          sufficient information concerning the income of the estate to               
          file the return and thus requested an extension of time to file             
          the return until January 15, 2003.  Mr. Poppo went on to explain            
          that he mistakenly believed that he had filed the estate’s tax              
          return and paid the taxes due before the January 15, 2003,                  
          deadline and that it was not until several months later when the            
          check had not cleared that he realized the return had not been              
          filed.  On November 17, 2003, the Cincinnati Service Center                 
          issued a notice that the request for abatement was denied.                  
              Mr. Poppo, represented by counsel, then filed an appeal with           
          respondent’s Appeals Office.  Mr. Poppo’s letter to Appeals,                
          dated December 26, 2003, reprised his earlier argument raised               
          before the Cincinnati Service Center concerning his mistaken                
          belief that the estate’s tax return had been filed and taxes paid           
          timely.  Mr. Poppo further argued for abatement because of his              
          lack of experience as an executor, the small but complicated                
          assets and income of the estate, and the large number of                    
          beneficiaries of the estate.  In subsequent correspondence and              

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