Charles R. Bowden and Sue I. Bowden - Page 45

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            authority has been shown to support petitioners’ deductions and                            
            failure to report income from various sources.                                             
                  We hold, to the extent that an understatement exists,                                
            petitioners are liable for the addition to tax under section                               
            6661(a) for 1986 and the accuracy-related penalty pursuant to                              
            section 6662(a) and (b)(2) for 1989.  For 1989, a single penalty                           
            of 20 percent is imposed under section 6662 though the                                     
            underpayment for that year is attributable to both negligence and                          
            substantial understatement.                                                                
            I.  Failure To Timely File Their Return                                                    
                  Respondent determined that petitioners are liable for an                             
            addition to tax for the failure to timely file a return.  Section                          
            6651(a)(1) imposes an addition to tax for failure to file a                                
            timely income tax return.  Petitioners bear the burden of showing                          
            respondent’s determination to be in error and that there was                               
            reasonable cause for their failure to timely file.  Rule 142(a).                           
                  Petitioners' 1986 and 1989 Federal income tax returns were                           
            filed during July 1988 and October 1990, respectively.                                     
            Petitioners contend that they did not file because they were                               
            unable to pay the income tax due in both taxable years due to                              
            “insufficient funds”.  Petitioners have not demonstrated that                              
            their lack of funds was a reasonable cause for their failure to                            
            timely file.  Therefore, to the extent of any tax required to be                           
            shown, which was not shown, petitioners are liable for the                                 





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