Which of the following statements regarding the assessment of penalties is correct?

(1) section 6651 provides for penalties for both late filing and late payment.

(2) penalties apply to the willful attempt to EV payment of estate and GST tax.

(3) A late filing penalty will not be imposed if the taxpayer can show that the failure to file a timely return is due to reasonable cost.

(4) all of the above statements are correct.