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and not due to willful neglect. Petitioners presented no
evidence to establish reasonable cause for the delinquent filing
of their return. Respondent, therefore, is sustained on this
issue. However, the addition to tax under section 6651(a)(1) is
5 percent of the "amount required to be shown as tax on * * *
[the] return." Section 6651(b)(1) provides that, for purposes of
computing the addition to tax, "the amount of tax required to be
shown on the return shall be reduced by the amount of any part of
the tax which is paid on or before the date prescribed for
payment of the tax". The original return filed by petitioners
for 1989 showed a tax of $11,670 and Federal income taxes
withheld of $90. That left a balance due of $11,580. The
return, as noted earlier, was filed on October 30, 1990. In the
amended return filed by petitioners for 1989, on which the
foreclosure loss was claimed, petitioners' tax was shown to be
$6,250 rather than $11,670, as shown on the original return.
Petitioners presented no evidence to show that "the amount of tax
required to be shown on the return" was paid on or before the due
date prescribed for payment of the tax, except for $90 in
withheld taxes. It is evident, and the Court holds, that
petitioners are not entitled, under section 6651(b)(1), to a
reduction in the amount of tax required to be shown on the return
by the amount of taxes they paid when they filed their delinquent
return for 1989. To determine the amount of the addition to tax
under section 6651(a)(1) and the amount of the credit or refund,
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