- 12 -
Commissioner, 864 F.2d 1521, 1527 (10th Cir. 1989), affg. 86 T.C.
492 (1986); Olsen v. Commissioner, supra. Consequently, we hold
that petitioners have not established reasonable cause for their
failure to file timely their 1990 tax return. Accordingly,
petitioners are liable for the section 6651(a)(1) addition to tax
relating to their tax liability for taxable year 1990.
To reflect the foregoing and the parties’ concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011