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year 1985, and they deducted only that amount, petitioners'
interest expense deduction was proper. Accordingly we sustain
petitioners as to the $1,032 interest expense deduction.
With regard to the additional interest deductions, we have
considered petitioners' arguments and find them to be without
merit.
Issue 3. Addition to Tax--Failure To Timely File
Respondent has determined an addition to tax under section
6651(a) for failure to file timely a Federal income tax return
for the tax year 1985.
In the case of a failure to file an income tax return within
the time prescribed by law, section 6651(a)(1) provides for an
addition to tax in the amount of 5 percent of the tax required to
be shown on the return for each month (or part thereof) during
which such failure continues, but not to exceed 25 percent in the
aggregate. See sec. 301.6651-1(a)(1), Proced. & Admin. Regs.
The taxpayer is not liable for the addition to tax if the failure
to file is due to reasonable cause and not due to willful
neglect. Sec. 6651(a)(1); Rule 142(a); United States v. Boyle,
469 U.S. 241, 245 (1985); Stovall v. Commissioner, 762 F.2d 891,
895 (11th Cir. 1985), affg. T.C. Memo. 1983-450. Taxpayers have
the burden of proving that their late filing of their return was
due to reasonable cause. Adamson v. Commissioner, 745 F.2d 541
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