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here have stipulated that petitioners' 1988 and 1989 joint
Federal income tax returns were not received by respondent until
more than 5 months after their due dates, as extended.
Petitioners, both of whom are experienced tax return preparers,
testified that they had also timely mailed returns to respondent,
and the returns that were received by respondent had been sent in
response to notices from respondent. Respondent had no record of
receiving any returns from petitioners for 1988 or 1989, other
than the ones that were untimely received and the unsigned
version that was received by respondent's agent. The unsigned
return received by respondent's agent would have also been more
than 5 months delinquent on the date received.
We do not accept petitioners' uncorroborated testimony that
they had timely mailed returns to respondent. They did not
provide any details concerning the preparation and mailing of the
returns and, because they also failed to file State returns,
cannot corroborate the existence of a Federal return's having
been attached to timely State returns for the same taxable
periods. Petitioners' suggestion that respondent did not receive
their allegedly timely filed returns 2 years in a row is
uncorroborated and not credible. Accordingly, we hold that
petitioners are liable for 25-percent additions under section
6651 for failing to timely file their 1988 and 1989 joint Federal
income tax returns.
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