Mitchell Wayne Andrew and Nancy Rae Patten - Page 9

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               Respondent established that petitioners’ 2000 return was not           
          filed by its extended due date.  Petitioners’ only explanation              
          for the untimely filing is their uncertainty as to how to treat             
          the Social Security disability payments.  We are not persuaded              
          that their explanation rises to the level of “reasonable cause”.            
          Accordingly, we hold that petitioners are liable for the addition           
          to tax under section 6651(a)(1) for the year 2000.                          
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

























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