Alonzo and Emma J. Bradley - Page 16

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          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.                            









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