Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax return in the amount of $110,644.42. Concessions having been made, the parties are agreed that the correct deficiency is $41,074.14. The sole issue for our determination is whether the failure to timely file the estate tax return was due to "reasonable cause" so as to prevent the imposition of an addition to tax in the stipulated...
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