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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.
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