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had they filed an application for extension of time to file. The
fact remains that no such extension was applied for or granted.
We also reject petitioners’ argument that the late filing
addition to tax should not be applied to them in light of
discussions which they allegedly had with respondent’s agent
regarding the untimely filing. Bauman’s testimony as to the
nature of these discussions was self-serving, and the record
lacks evidence to corroborate his testimony. Accordingly,
respondent’s determination as to this issue is sustained.
To reflect the foregoing,
Decisions will be
entered under Rule 155.
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