United States Federal Circuit

The decision of the United States Court of Federal Claims that upheld a penalty assessed by the Internal Revenue Service because the executor filed the estate-tax return late is affirmed, where: 1) under the relevant statute, as the case is presented here, the full assessed penalty was mandatory unless advice given by counsel established reasonable cause for not filing the return during a nine-month period from August 2005 to May 2006; and 2) the trial court properly found no reasonable cause.

Appellate Information

• Decided 06/10/2014
• Published 06/10/2014

Judges

• TARANTO

Court

• United States Federal Circuit

Counsel