Wayne and June Ellen Hairston - Page 26

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          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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