The decedent died with a large estate and with two grandchildren as his only heirs. By the filing deadline for the estate tax return, the estate filed a request for an extension of time to file and paid $6.5 million in federal estate tax, a portion of the estate tax due. The estate only made partial payment of estate tax due to legal advice that the estate might be able to elect installment payment under I.R.C. Sec. 6166. The estate did receive a six-month extension to file. The estate filed by the extended due date, but did not elect installment payment treatment. The estate also requested an extension of time to pay. The IRS denied an extension of time to pay and imposed a failure-to-pay penalty. The estate then paid the estate tax due and a penalty of nearly $1 million, plus interest. The estate then sued for a refund of the penalty and interest. The trial court granted summary judgment for IRS. On appeal, the court vacated the trial court's decision and remanded the case. The court noted that the estate relied on the faulty advice of a tax "expert" and that could constitute reasonable cause for failure to pay by the deadline if the taxpayer can show either an inability to pay or undue hardship from paying at the deadline. Estate of Thouron v. United States, No. 13-1603, 2014 U.S. App. LEXIS 8890 (3d Cir. May 13, 2014).