Estate of Clarence I. Lillehei, Deceased. James P. Lillehei v. Commissioner of Internal Revenue

Appellant James P. Lillehei challenges the United States Tax Court’s decision that he as executor of the Estate of Clarence I. Lillehei did not show reasonable cause for the late filing of the estate’s federal estate-tax return.

This action was brought by the executor in the United States Tax Court to abate the assessment of penalties imposed by the Commissioner of Internal Revenue for late filing under sections 6651(a)(1) and (2) of the Internal Revenue Code of 1954. The case was tried at St. Paul, Minnesota, on March 26, 1979, before Judge Quealy. In Tax Court Memo 1979-464, filed on…