- 26 -
Commissioner, T.C. Memo. 1980-350. Accordingly, petitioners'
dispute with the State and Federal taxing authorities concerning
their tax liability for the taxable years 1988 and 1989 does not
constitute reasonable cause for petitioners' failure to file
their 1990 return in an untimely manner. We therefore sustain
respondent on this issue.
Conclusion
To give effect to our resolution of the disputed issues, as
well as the parties' concessions,
Decisions will be entered
under Rule 155.
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