Rodney W. Taras and Linda K. Taras - Page 26

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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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