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from the years 1990 through 1992. The only evidence offered by
petitioners in support of that position is their general, vague,
and conclusory testimony, Mr. Owens’ return for 1990, and peti-
tioners’ joint returns for 1991 and 1992. Although each of the
returns for 1990, 1991, and 1992 shows a loss attributable to
petitioners’ Schedule C business, petitioners failed to introduce
any evidence establishing the loss claimed in each of those
returns. The returns for 1990 through 1992 constitute nothing
more than the position of petitioners that they had the respec-
tive losses claimed in those returns.
Based on our examination of the entire record before us, we
find that petitioners have failed to show that they are entitled
for any of the years at issue to a net operating loss deduction.
Addition to Tax Under Section 6651(a)(1)
Respondent determined that petitioners are liable for the
addition to tax under section 6651(a)(1) because they filed their
1993 joint return on December 27, 1996, and their 1994 and 1995
joint returns on December 26, 1996.
Section 6651(a)(1) imposes an addition to tax for failure to
file timely a tax return. The addition to tax does not apply if
the failure is due to reasonable cause, and not to willful
neglect. See sec. 6651(a)(1).
As we understand petitioners’ position, they contend that
they should not be held liable for the additions to tax under
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