- 36 -
extensions for 1987 though 1990 were valid and argue that the
addition should only apply from the respective due dates as
extended.
The Suttons have not shown they made a bona fide and
reasonable estimate of their tax liability at the time the
requests for extension were made. We hold for respondent on this
issue.
Additions to Tax and Penalties for Negligence
Respondent has determined that all of the Suttons'
understatements for the years at issue were due to negligence or
disregard of rules or regulations.11 The individual petitioners
have argued only that they correctly reported their income and
were not otherwise negligent. We disagree. They have presented
no specific evidence that they acted as would a reasonable and
ordinarily prudent person under the circumstances. We sustain
respondent on the negligence issue.
Addition to Tax under Section 6661
Respondent has determined additions to tax for substantial
11 The additions to tax and penalties are under the
following sections:
Year Sections
1986 Sec. 6653(a)(1)(A) and (B)
1987 Sec. 6653(a)(1)(A) and (B)
1988 Sec. 6653(a)(1)
1989 Sec. 6662(a)
1990 Sec. 6662(a)
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011