who was responsible for preparing the estate tax return. Resolution of the question presented in this suit does not require assigning fault for this misunderstanding. 5 . See supra n. 1. 6 . Where an agency is tasked with administering a statute, as the IRS is tasked with administering the Internal Revenue Code, the agency’s interpretation of ambiguous language in that statute is entitled to deference provided it is based on a reasonable construction of the statute. See Regis v. Holder, 769 F.3d 878, 881 (4th Cir.2014) (citing Chevron v. Natural Res. Def. Council, Inc., ,467 Ú.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984)). The parties offer no reason to doubt that the IRS’s interpretation of § 6651(a), as reflected in the regulation, is entitl F.3d 1164, 1171 (9th Cir.2013) (<HOLDING>); McMa-han v. Comm’r, 114 F,3d 366, 371 (2d
holding that it is inconsistent with ordinary business care and prudence to rely unquestioningly on advice about an extended deadline holding that seamen are also held to a standard of ordinary prudence to avoid injury holding that under either theory the duty is the same ordinary care holding employers to an ordinary prudence standard of care holding that premises owner had duty to use degree of care in performing activities that owner of ordinary prudence would use under same or similar circumstances