Allen C. Chamberlin and Martha L. Chamberlin - Page 27

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          addition to tax of 0.5 percent per month up to 25 percent for               
          failure to pay the amount shown or required to be shown on a                
          return.  A taxpayer may fail to file and pay a tax and thus be              
          subject to both section 6651(a)(1) and (2).  See sec. 6651(c)(1).           
          If that occurs, the amount of the addition to tax under section             
          6651(a)(1) is reduced by the amount of the addition to tax under            
          section 6651(a)(2) for any month to which an addition to tax                
          applies under both paragraphs (1) and (2).  The combined amounts            
          under paragraphs (1) and (2) cannot exceed 5 percent per month.             
          See sec. 6651(c)(1).                                                        
               To escape the additions to tax for filing late returns,                
          petitioners have the burden of proving that the failure to file             
          did not result from willful neglect and that the failure was due            
          to reasonable cause.  See United States v. Boyle, 469 U.S. 241,             
          245 (1985).  Reasonable cause requires taxpayers to demonstrate             
          that they exercised "ordinary business care and prudence" but               
          nevertheless were "unable to file the return within the                     
          prescribed time."  Sec. 301.6651-1(c)(1), Proced. & Admin. Regs.            
               Petitioners argue that they used ordinary business care and            
          prudence because they were acting at all times upon the advice of           
          a certified public accountant who prepared their returns.                   
          Petitioners also claim that, due to their financial crisis at the           

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