- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011