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Once again, petitioners have presented no persuasive
evidence on this issue, and the record does not otherwise
establish that their failure to file timely returns was due to
reasonable cause and not due to willful neglect. In this regard,
we find unpersuasive petitioners’ claim that they should be
relieved of the addition to tax because their new accountant for
1997 was unable to timely receive information from the former
accountant as to the basis of certain stock that they sold. We
see no reason why the return was not filed timely. We sustain
respondent’s determination under section 6651(a).
All arguments made by petitioners but not discussed herein
have been considered and have been found to be without merit.
Accordingly,
Decision will be entered
under Rule 155.
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