Bidyut K. Bhattacharyya and Diana T. Bhattacharyya - Page 35

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          hold that petitioners are liable for a section 6651(a)(1)                   
          addition to tax.20                                                          
          VII. Conclusion                                                             
               Based on the above, petitioners are liable for an increased            
          deficiency in income tax, an increased addition to tax under                
          section 6651(a)(1), and are not entitled to a refund.                       
               In reaching our holdings, we have considered all arguments             
          made, and, to the extent not mentioned, we conclude that they are           
          moot, irrelevant, or without merit.                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          















               20  Because petitioners filed their return more than 25                
          months after it was due, the addition to tax under sec.                     
          6651(a)(1) will be 25 percent of the amount required to be shown            
          as a tax on the return.  See sec. 6651(a)(1).  The amount of the            
          addition to tax should be determined by the parties as part of              
          their Rule 155 computations.                                                




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