- 16 - Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Petitioners' return was due on April 15, 1993, and was not filed until on or about April 26, 1993. Petitioners argued that they did not believe they owed any tax, but their mistaken belief is not reasonable cause for failure to timely file a return. Linseman v. Commissioner, 82 T.C. 514, 523 (1984); Cox v. Commissioner, 54 T.C. 1735, 1744 (1970). Therefore, we find petitioners liable for the addition to tax under section 6651(a)(1). Penalty for Substantial Understatement of Tax Respondent also determined that petitioners are liable for the accuracy-related penalty for substantial understatement of tax under section 6662(b)(2). Since petitioners have not provided substantial authority for the positions taken on their return, or made any disclosure within the meaning of section 6662(d)(2)(B)(ii), the penalty is sustained in the event that the Rule 155 computation indicates that petitioners' understatement of tax exceeds the greater of $5,000 or 10 percent of the amount of tax required to be shown on the return. To reflect the foregoing and concessions, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011