Mary Ann and Wilson R. Collins - Page 11

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            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.                                                                              

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