Mary T. King and Fatai O. King - Page 23




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             willful neglect".  The addition is 5 percent of the amount                 
             of the tax required to be shown on the return for each                     
             month the failure continues, not exceeding 25 percent in                   
             the aggregate.                                                             
                  In this case, petitioners filed their return more than                
             1 month after the due date.  Respondent determined that                    
             petitioners are liable for an addition to tax of $2,736                    
             pursuant to section 6651(a)(1).  Petitioners did not                       
             address this issue in their petition, in their trial                       
             memorandum, at trial, or in their posttrial brief.  By                     
             failing to address the issue, petitioners have conceded                    
             it.  See Money v. Commissioner, supra.  Accordingly, we                    
             find petitioners are liable for an addition to tax under                   
             section 6651(a)(1).                                                        
                  Based upon the foregoing,                                             


                                            Decision will be entered                    
                                        under Rule 155.                                 

















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