Howard Howe and Janice Howe - Page 9




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          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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