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Respondent determined additions to petitioners' 1986, 1987
and 1988 income tax under section 6651(a)(1), asserting that
petitioners failed to timely file Federal income tax returns for
those years. Petitioners filed all of these returns in 1990.
Thus, in order to avoid this addition to tax, petitioners must
prove that their failure to file timely was: (1) Due to
reasonable cause and (2) not due to willful neglect. Sec.
6651(a); Rule 142(a); United States v. Boyle, 469 U.S. 241,
245 (1985); Buelow v. Commissioner, 970 F.2d 412, 415 (7th Cir.
1992), affg. T.C. Memo. 1990-219; Church of Scientology v.
Commissioner, 823 F.2d 1310, 1321 (9th Cir. 1987), affg. 83 T.C.
381 (1984); Catalano v. Commissioner, 81 T.C. 8 (1983), affd.
without published opinion sub nom. Knoll v. Commissioner, 735
F.2d 1370 (9th Cir. 1984). A failure to file a timely Federal
income tax return is due to reasonable cause if the taxpayer
exercised ordinary business care and prudence and, nevertheless,
was unable to file the return within the prescribed time. Sec.
301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect means a
conscious, intentional failure to file or reckless indifference.
United States v. Boyle, supra at 245.
Petitioners claim that they are not liable for the addition
to tax under section 6651(a)(1) because their accountant advised
them that they had no obligation to file returns for 1986, 1987
or 1988. We find it implausible that petitioners' accountant
would advise petitioners that they did not have an obligation to
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