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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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