- 11 - and not due to willful neglect. Petitioners presented no evidence to establish reasonable cause for the delinquent filing of their returns. Although petitioner claimed that their return preparer was supposed to have filed applications for extensions to file, which he failed to do, the Court is skeptical of this contention. For example, the 1989 return, which should have been filed on or before April 16, 1990, was filed on June 11, 1992, over 2 years beyond the due date. Petitioner did not testify as to the date the return preparer was engaged to prepare petitioners' returns. Since the 1989, 1990, and 1991 returns bear almost identical signature dates, it is logical for the Court to conclude that petitioners, in all probability, did not engage the services of the return preparer until sometime in 1992, when the returns were signed. This would have been past the due date for filing the returns. Petitioners have not established reasonable cause for the late filing of their returns. Respondent is sustained 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