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to a maximum of 25 percent of the tax. Id. The addition to tax
is applicable unless petitioners establish that the failure to
file was due to reasonable cause and not willful neglect. Id.
Petitioners bear the burden of establishing that they are not
liable for these additions to tax. Rule 142(a).
Petitioners filed their 1991 Federal tax return on September
21, 1992, 36 days after the filing deadline under the automatic
extension. Petitioners filed their 1992 tax return on February
24, 1994, 4 months and 9 days after the filing deadline as
extended. Petitioners have not established that their late
filings were due to reasonable cause. Accordingly, we sustain
respondent on this issue.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011