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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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