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self-employment tax, and petitioners’ 1994 Federal income tax
return due to be filed on or before April 15, 1995, was filed on
January 9, 1996, and, therefore, was untimely. Furthermore,
petitioners offered no evidence whatsoever that their failure to
timely file their return was due to reasonable cause and not due
to willful neglect. In view of the above, respondent is
sustained on these issues.
Inasmuch as we have sustained respondent on these two
issues, respondent’s oral motion for entry of decision is deemed
moot.
To reflect the foregoing,
Decision will be entered
for respondent.
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