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that such failure is due to reasonable cause and not willful
neglect. Petitioners’ 1994 tax return was signed February 18,
1997. Petitioners presented no evidence and did not offer any
explanations as to why they failed to file timely their 1994
return. Neither petitioners’ trial memorandum nor their opening
brief mentioned the late filing of their return. They are thus
deemed to have conceded the issue. They belatedly claim in their
reply brief that they were not given enough time to address this
issue. The trial of this case substantially exceeded the time
estimated by the parties. Much time was wasted by petitioner’s
refusal to execute an appropriate stipulation or to heed the
Court’s attempts to direct his testimony to relevant facts.
Petitioners are liable for the addition to tax for 1994.
We have considered petitioners’ remaining arguments. To the
extent that they are not discussed above, those arguments are
totally lacking in merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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