- 26 - 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.]Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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