- 5 -
Commissioner, 74 T.C. 260, 268-269 (1980), affd. in part, revd.
in part on other grounds, and remanded 649 F.2d 152 (2d Cir.
1981); Veto v. Commissioner, T.C. Memo. 1993-557. We also note
that Mrs. Labato was not incarcerated and could have filed on
time. Petitioners failed to prove that they had reasonable
cause. Accordingly, we find for respondent as to the addition to
tax under section 6651(a)(1).
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011