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conclude otherwise. On this record, the Court finds that
petitioners mailed their return on October 12, 2002, and the
failure of that return’s being delivered to the IRS within a
reasonable time period was due to circumstances not within
petitioners’ control. The failure to file the duplicate return
timely, therefore, was due to reasonable cause. Petitioners,
therefore, are sustained on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011