William David and Judith A. Jamieson - Page 9

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            claimed by them was calculated improperly.5  Petitioners,                                  
            therefore, are also liable for the addition to tax under section                           
            6653(a)(1).                                                                                


            Decision will be entered                                                                   
            for petitioners for 1986 and                                                               
            for respondent for 1987.                                                                   


























            5     Furthermore, the untimely filing of petitioners' return was                          
            negligent.  See Emmons v. Commissioner, 92 T.C. 342 (1989), affd.                          
            on other grounds 898 F.2d 50 (5th Cir. 1990).                                              




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