Bernard L. Nadeau, Jr. and Nancy L. Nadeau - Page 11

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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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