- 35 -
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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