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ESTATE OF THOMAS v. COMMISSIONER

Docket No. 15734-99.

82 T.C.M. 449 (2001)

T.C. Memo. 2001-225

Estate of Michael J. Thomas, Deceased, Helen Z. Thomas, Executor v. Commissioner.

United States Tax Court.

Filed August 15, 2001.

Attorney(s) appearing for the Case

William J. Abraham, for the petitioner. John J. Boyle, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

Respondent determined that the estate was liable for the addition to tax under section 6651(a)(1), in the amount of $3,591, for failure to file its Federal estate tax return timely.1 Based upon the estate tax return that was filed and the estate taxes shown on the return, respondent assessed additions to tax under section 6651(a)(1) and (2) in the respective amounts of $24,952...

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