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is no evidence in the record to support this contention, and we
reject it. We sustain respondent's determination on this issue.
The third issue for decision is whether petitioners are
liable for the section 6651(a)(1) addition to tax for failure to
timely file their 1992 Federal income tax return.
Section 6651(a) imposes an addition to tax for the failure
to timely file a return, unless the taxpayer establishes: (1)
The failure did not result from "willful neglect," and (2) the
failure was "due to reasonable cause". "Willful neglect" has
been interpreted to mean a conscious, intentional failure or
reckless indifference. United States v. Boyle, 469 U.S. 241,
245-246 (1985). "Reasonable cause" requires the taxpayer to
demonstrate that he exercised ordinary business care and prudence
and was nonetheless unable to file a return within the prescribed
time. United States v. Boyle, supra at 246. The addition to tax
equals 5 percent of the tax required to be shown on the return
for the first month with an additional 5 percent for each
additional month or fraction of a month during which the failure
to file continues, not to exceed a maximum of 25 percent. Sec.
6651(a)(1).
Petitioner husband claims that petitioners timely filed
their 1992 Federal income tax return because of the extensions
approved by respondent. Petitioners' 1992 return was filed with
respondent on November 11, 1993. Petitioners' Form 2688,
attached to their 1992 return, shows that respondent approved an
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