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States v. Boyle, supra; see also Radabaugh v. Commissioner, T.C.
Memo. 1992-572; Massengill v. Commissioner, T.C. Memo. 1986-159.
Even if petitioners were told by a return preparer that it was
unnecessary to file a return, that would not excuse them from the
late filing addition in the absence of proof that adequate
disclosure of their income was made to the preparer.
We hold that petitioners are liable for the late filing
addition to tax under section 6651(a)(1), the amount to be
determined under Rule 155.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011