- 7 - that petitioners’ mistaken belief that they did not owe any tax is not reasonable cause for failure to timely file a return. Accordingly, respondent’s determination with respect to the additions to tax under section 6651(a)(1) is sustained. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011