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basis of a calendar year must be filed on or before April 15,
following the close of the calendar year unless the due date is
extended. Sec. 6072(a). On brief respondent notes that
petitioners’ 2003 return was due on October 15, 2004 (presumably
on account of an extension of time to file). Petitioners filed
their 2003 return on November 18, 2004. Accordingly, respondent
has met his burden of production on this issue.
Petitioners claimed their failure to timely file for 2003
was due to reasonable cause and not willful neglect because Mr.
Arnold was ill at the time. Petitioners rely on their own
testimony.
The Court is not required to accept petitioners’
unsubstantiated testimony. See Wood v. Commissioner, 338 F.2d at
605. The Court need not accept at face value a witness’s
testimony that is self-interested or otherwise questionable. See
Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg.
a Memorandum Opinion of this Court; Weiss v. Commissioner, 221
F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51;
Schroeder v. Commissioner, T.C. Memo. 1986-467. This is so even
when the testimony is uncontroverted if it is improbable,
unreasonable, or questionable. Archer v. Commissioner, supra at
273; Weiss v. Commissioner, supra at 156; see Quock Ting v.
United States, 140 U.S. 417 (1891). We found petitioners’
testimony to be conclusory and/or questionable in certain
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