- 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.Page: Previous 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158
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