M.S. Food Stores, Inc. - Page 36

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          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)                                            





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