Robert A. Inzano and Martha O. Chavez - Page 12

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          Commissioner, 864 F.2d 1521, 1527 (10th Cir. 1989), affg. 86 T.C.           
          492 (1986); Olsen v. Commissioner, supra.  Consequently, we hold            
          that petitioners have not established reasonable cause for their            
          failure to file timely their 1990 tax return.  Accordingly,                 
          petitioners are liable for the section 6651(a)(1) addition to tax           
          relating to their tax liability for taxable year 1990.                      
               To reflect the foregoing and the parties’ concessions,                 


                                                  Decision will be entered            
                                             under Rule 155.                          




























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