- 14 - Alaska to Texas and for the purchase of a truck and a trailer in Texas. Addition to Tax Under Section 6651(a)(1) 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 ne- glect. See sec. 6651(a)(1). Petitioners’ joint return for 1993 was received by respondent on April 9, 1997. Petitioners intro- duced no evidence and advanced no contentions at trial regarding respondent’s determination to impose for 1993 the addition to tax under section 6651(a)(1). On the instant record, we find that petitioners have failed to carry their burden of establishing that they are not liable for 1993 for the addition to tax under section 6651(a)(1). We have considered all of the arguments and contentions of petitioners that were advanced at trial, which are not discussed herein, and we find them to be without merit and/or irrelevant. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011