11 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011