Larry M. Petty and Jean L. Petty - Page 14




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          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.                                     













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