Paul L. Blanton and Cynthia D. Blue-Blanton - Page 17

                                        -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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