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business. Petitioners established that they are just as
determined to earn a profit with Ascension.
II. Section 6651 Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
file a required return on the date prescribed, unless it is shown
that such failure is due to reasonable cause and not willful
neglect. Petitioners have not shown that such failure to file by
the prescribed date was due to reasonable cause and not willful
neglect. Accordingly, petitioners are liable for the 1994
addition to tax.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011