Tommy Owens, Jr. and Dawn R. Owens - Page 22




                                       - 22 -                                         
          section 6651(a)(1) because, when the return for each of the years           
          at issue was due, they were involved in respondent’s examination            
          of their taxable years 1990 through 1992, and they did not                  
          believe that they owed any tax.  On the record before us, we find           
          that those reasons do not constitute reasonable cause for pur-              
          poses of section 6651(a)(1).12                                              
               Based on our examination of the entire record before us, we            
          find that petitioners have failed to establish that their failure           
          to file timely the joint returns in question was due to reason-             
          able cause, and not due to willful neglect.  Consequently, we               
          sustain respondent’s determinations that petitioners are liable             
          for each of the years at issue for the addition to tax under                
          section 6651(a)(1).                                                         
               We have considered all of the contentions and arguments of             
          petitioners that are not discussed herein, and we find them to be           
          without merit and/or irrelevant.                                            
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               





               12See Klyce v. Commissioner, T.C. Memo. 1999-198; Likes v.             
          Commissioner, T.C. Memo. 1991-286; see also Ferguson v. Commis-             
          sioner, T.C. Memo. 1994-114; Knight v. Commissioner, T.C. Memo.             
          1984-376.                                                                   






Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  

Last modified: May 25, 2011