88. Heather had named Brenda the executrix of her estate. Brenda had no experience in this domain, but she filed the return, and the estate paid a Federal death tax of $2 million. This year, Heather’s son Dylan, studying for a master’s degree in taxation, discovered that Brenda had not reported any of Heather’s realty in the gross estate and that an additional $250,000 in taxes and interest is due. The IRS then assessed various penalties, totaling $30,000. How can the estate, now administered by Dylan, avoid this penalty?