Mila Alemasov and Victor Popov - Page 21




                                       - 21 -                                         
          913 (1989) (section 6651(a) addition to tax upheld where                    
          taxpayers failed to show what records were needed or what actions           
          they took to obtain such records).                                          
               To support the claim that their return preparer requested an           
          additional extension of time to file their 2002 return,                     
          petitioners offered an unsigned copy of a Form 2688 and contend             
          that this is similar to what was submitted.  Notwithstanding                
          their attempt to shift responsibility for their late filing to              
          their return preparer, such reliance on one’s accountant or                 
          return preparer does not constitute “reasonable cause” for a late           
          filing under section 6651(a).  United States v. Boyle, supra at             
          252; see also Ruddel v. Commissioner, supra.  On this record, the           
          Court holds that petitioners are liable for the section                     
          6651(a)(1) addition to tax.                                                 
               The Court has considered all other arguments advanced by the           
          parties, and, to the extent those arguments have not been                   
          specifically addressed, the Court concludes they are without                
          merit.                                                                      

                                                  Decision will be entered            
                                             under Rule 155.                          












Page:  Previous  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21

Last modified: November 10, 2007