- 9 - 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).Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011