- 9 -
personal knowledge of his tax liabilities. We give the chart no
weight because it is completely uncorroborated. Petitioners did
not offer into evidence the underlying information that petitioner
claims to have summarized on the chart, such as canceled checks
showing tax payments, or returns from other years showing treatment
of alleged overpayments.
Petitioners contend that they reasonably believed that they
owed no tax for 1992. Petitioner did not explain what led him to
that belief. We are not convinced that petitioners had reasonable
cause for filing their 1992 return late. Thus, petitioners are
liable for the addition to tax under section 6651(a)(1) for 1992.
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011