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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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