- 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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