Srichai and Pusadee Rungrangsi - Page 17

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          expenses would already be allowed and provided for in the                   
          reconstruction of petitioners' restaurant income.  And, in fact,            
          petitioners did report on Schedules C interest expenses of $9,938           
          for 1992 and $12,100 for 1993.  Thus, to both allow deductions for          
          these interest expenses on Schedules C and for trade or business            
          interest expenses on Schedules A would amount to the allowance of           
          double deductions.  Consequently, respondent's determination                
          disallowing $12,221 of interest expenses for 1992 and $10,277 of            
          interest expenses for 1993 is sustained.                                    
          Issue 4.  Failure To File Additions to Tax                                  
               The fourth issue for decision is whether petitioners are               
          liable for the addition to tax pursuant to section 6651(a)(1) for           
          failing to timely file their income tax returns for each of the             
          years in issue.                                                             
               Section 6651(a)(1) imposes an addition to tax of 5 percent for         
          each month or fraction thereof in which an income tax return is not         
          filed after the prescribed filing date.  An exception is made for           
          reasonable cause not due to willful neglect.                                
               Although the record on this issue is vague, petitioners                
          concede that they did not timely file their tax returns for the             
          years in issue.  Respondent contends that the 1992 return was filed         
          on August 18, 1993, the 1993 return was filed on June 1, 1994, and          
          the 1994 return was filed on May 14, 1995.                                  

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