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reasonable cause and not willful neglect. Niedringhaus v.
Commissioner, 99 T.C. 202, 220-221 (1992). Petitioners filed
their tax returns for the tax years 1987, 1988, and 1989 on
August 23, 1991, and their tax return for the tax year 1990 on
June 19, 1992. Petitioners have failed to show that their
failure to file returns for the taxable years 1987 through 1990
was due to reasonable cause and not willful neglect. Petitioners
are liable for the additions to tax under section 6651(a)(1) for
the taxable years 1987 through 1990.
Decision will be entered
under Rule 155.
[The appendix is a 1-page spreadsheet in Lotus format
that is incompatible with the Wordperfect format of
this opinion. A copy of the appendix may be obtained
from chambers.]
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