Respondent, by letter dated December 11, 1962, notified the executor of the estate of William T. Mayer that the determination of the estate tax liability of the estate disclosed "a deficiency in penalty" in the amount of $3,466.89.
At issue is whether the failure timely to file the estate tax return was due to reasonable cause so as to make inapplicable the addition to tax provided for in section 6651 of the 1954 Code.
FINDINGS OF FACT
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