-17-
October 15, 1993. Mr. Blanton did not testify that Schmitz told
them they had an additional extension of time to file their 1992
return beyond the October 15, 1993, due date, call Schmitz to
testify, or provide any correspondence from Schmitz corroborating
his testimony.
Petitioners did not have reasonable cause for filing their
1992 return more than 9 months after their extensions expired.
Thus, they are liable for the addition to tax under section
6651(a)(1).
To reflect the foregoing,
Decision will be entered
for respondent.
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