- 597 -
percent for each additional month or fraction thereof during
which such failure continues, not exceeding 25 percent in the
aggregate.
IRA failed to file timely its Federal income tax return for
1980. Although the due date for IRA's filing of its 1980 return
had been extended to September 15, 1981, the return was not
received by the Internal Revenue Service until on or about
November 21, 1981. See Issue 30. IRA has not shown that such
failure to file timely the return was due to reasonable cause and
was not due to willful neglect. Therefore, we hold that IRA is
liable for the section 6651(a)(1) addition to tax equal to 15
percent of the deficiency for 1980.
Issue 38. Whether IRA Is Liable for the Section 6653(a)
Additions to Tax for 1980, and 1982 Through 1988
OPINION
In the notices of deficiency to IRA for 1980 and 1982
through 1988, respondent determined that all of the underpayments
for each year were attributable to negligence or intentional
disregard of rules or regulations under section 6653(a).
IRA contends that it is not liable for the section 6653(a)
addition to tax because it reasonably relied upon the advice of
tax professionals, including Kanter and the certified public
accountants who maintained its books and prepared its tax
returns.
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