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ESTATE OF DiPALMA v. COMMISSIONER

Docket No. 5207-76.

71 T.C. 324 (1978)

ESTATE OF AGNESE DIPALMA, CONSTANCE SAVARESE, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 27, 1978.

Attorney(s) appearing for the Case

Ira W. Levitas, for the petitioner.

Jack H. Klinghoffer, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in estate tax of $2,760.19 and an addition to tax of $10,748.77 under section 6651(a).1 Two issues require decision: (a) whether the admitted delay in the filing of the estate tax return was due to reasonable cause and not to willful neglect, and (b) what was the balance at the date of death in a joint account held by the decedent and one of her daughters.

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