Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency of $527.02 for the year 1950. The deficiency arose because of the Commissioner's determination of a 20 per cent delinquency penalty under section 291(a), Internal Revenue Code of 1939.
The only question for decision is whether the failure of petitioners to file a timely joint income tax return was due to reasonable cause and not to willful neglect.<...
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