- 21 - Having business problems does not relieve taxpayers of the obligation to file timely Federal income tax returns. We sustain respondent's imposition of the addition to tax under section 6651(a)(1) for 1985 and 1986. Petitioners argue that they relied on their accountant to prepare proper income tax returns. The evidence, however, indicates that petitioners did not provide their accountant with accurate and complete records from which accurate tax returns could be prepared. See Hull v. Commissioner, T.C. Memo. 1991-582; Auld v. Commissioner, T.C. Memo. 1978-508. We sustain respondent's imposition of the additions to tax under section 6653(a)(1) and (2) for 1985, and under section 6653(a)(1)(A) and (B) for 1986 and 1987. Petitioners have not established that they had substantial authority for the positions taken on their joint Federal income tax returns, nor that the relevant facts were adequately disclosed on their returns. For each year in issue, we sustain the additions to tax under section 6661. An appropriate order denying petitioners' motion for reconsideration will be issued, and decision will be entered under Rule 155.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
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