- 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
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