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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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Last modified: May 25, 2011