- 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35
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