Estate of Thouron v. United States, No. 11-4058, 2012 U.S. Dist. LEXIS 159400 (E.D. Pa. Nov. 7, 2012)

(estate not entitled to refund of penalty where heirs needed additional time to determine extent of decedent's business affairs involving complex entities in multiple states but, in reliance on advice of estate's attorney, failed to file for extension of time to pay estate taxes).