Zinovy Brodsky - Page 74




                                       - 158 -                                         
          See United States v. Boyle, 469 U.S. 241 (1985).                             
               On the record before us, we find that petitioner has failed             
          to satisfy his burden of establishing that he had reasonable                 
          cause for his failure to file timely the 1993 joint return in                
          question.  On that record, we find that petitioner is liable for             
          1993 for the addition to tax under section 6651(a)(1).                       
               We have given due consideration to all of the parties’                  
          contentions and arguments, even though we have not addressed each            
          of them herein.                                                              
               To reflect the foregoing, the concessions of respondent, and            
          the matters abandoned by petitioner,                                         


                                              Decision will be entered under           
                                        Rule 155.                                      

























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