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ESTATE OF YOUNG v. U.S.

Civil Action No. 11-11829-RWZ.

THE ESTATE OF NANCY P. YOUNG v. UNITED STATES OF AMERICA

United States District Court, D. Massachusetts.

December 17, 2012.

MEMORANDUM AND ORDER

RYA W. ZOBEL, District Judge.

Plaintiff, the estate of Nancy P. Young ("the Estate"), filed its estate tax return after the applicable deadline and the IRS assessed a late-filing penalty. The Estate has sued the United States for a refund of that penalty on the ground that it had reasonable cause for its late filing. The United States now moves for summary judgment.

I. Background

The relevant facts are undisputed. Nancy...

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