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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.
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