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SMITH v. COMMISSIONER

Docket No. 27715-81.

47 T.C.M. 1233 (1984)

T.C. Memo. 1984-114

R. Bob Smith and Marjorie W. Smith v. Commissioner.

United States Tax Court.

Filed March 8, 1984.

Attorney(s) appearing for the Case

John E. Watson, for the petitioners. Jane T. Dickinson and Roy S. Fischbeck, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined an addition to petitioners' Federal income tax for the taxable year 1977 in the amount of $61 under section 6651(a)(1)1 for failure to timely file their return. The only issue for decision is whether petitioners' failure to timely file their 1977 Federal income tax return was due to reasonable cause and not due to willful neglect.

Findings...

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