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incorporated herein. At the time the petition was filed in this
case, petitioners resided in Anchorage, Alaska.
This case is part of a group of cases identified by
respondent as McIntyre-CN. McIntyre-CN is a national litigation
project involving coal mining partnerships promoted by Richard
McIntyre (McIntyre).
Petitioner husband (Bauman) has been employed as an attorney
with the same law firm (law firm) in Anchorage, Alaska, since
1973. He has been a partner in that law firm since 1975.
Petitioners timely filed their Federal income tax return for
1979. Petitioners’ Federal income tax return for 1980 was not
received by the Internal Revenue Service (IRS) until May 8, 1981.
Attached to petitioners’ return for taxable year 1980 is a brief
handwritten note in which Bauman explains the reason for the
untimely filing. This note essentially states that confusion
brought about by petitioner wife’s (Mrs. Bauman) second pregnancy
caused the couple to overlook the filing deadline. The note
concludes with the statement “it won’t happen again”.
Petitioners’ Federal income tax return for 1982 was not received
by the IRS until June 10, 1983. Attached to petitioners’ return
for taxable year 1982 is a brief typewritten note in which Bauman
explains the reason for the couple’s delinquent filing. In this
note, Bauman principally asserts that the couple was unable to
satisfy their obligation to file their return by the prescribed
date because Bauman’s father was ill and that such illness
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