- 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.Page: Previous 1 2 3 4 5 6 7 8 9
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