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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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Last modified: May 25, 2011