James R. and Myrtice L. Peacock - Page 33

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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.               

                                                  Decision will be entered            
                                             under Rule 155.                          

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