- 24 - and $55 for 1992. Thus, respondent has conceded that petitioners are not liable for additions to tax in excess of the amounts in the stipulation. Further, for 1990 and 1992 petitioners have conceded that with respect to the additions under section 6651(a), their failure to file tax returns was not due to reasonable cause; and, with respect to the additions under section 6654, they do not qualify for any exceptions to the additions in section 6654(e). The only remaining matters with respect to additions to tax are computational, which can be addressed in the Rule 155 computation. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011