Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $3,407.49 in petitioner's estate taxes and a penalty of $851.87 pursuant to section 6651(a)
The parties have agreed that there is a gross deficiency of $980.29 and the sole issue presented to us is whether there was reasonable cause for the late filing of the return.
Findings...
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