Raymond O. Wright - Page 11

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          vague and conclusory and does not even address the specifics of             
          his duties in that year.  We conclude that he has failed to                 
          demonstrate error in respondent's determinations of liability for           
          self-employment tax in 1987 and 1989 and accordingly sustain                
          them.                                                                       
          Additions to Tax Under Section 6651(a)(1)                                   
               Respondent determined additions to tax for failure to timely           
          file returns under section 6651(a)(1) with respect to both years            
          in issue.  Petitioner claims that his failure to file for these             
          years was due to reasonable cause.                                          
               Section 6651(a)(1) imposes an addition to tax for failure to           
          timely file a return unless it is shown that such failure is due            
          to reasonable cause and not due to willful neglect.  The amount             
          of the addition to tax is determined on a graduated basis,                  
          beginning at the rate of 5 percent of the amount required to be             
          shown on the return if the failure is not more than 1 month, with           
          an additional 5 percent for each additional month or fraction               
          thereof that such failure continues, not exceeding 25 percent in            
          the aggregate.  Sec. 6651(a)(1).                                            
               To prove reasonable cause, a taxpayer must show that he                
          exercised ordinary business care and prudence but nevertheless              
          was unable to file the return when it was due.  Crocker v.                  
          Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-1(c)(1),               
          Proced. & Admin. Regs.  Petitioner argues that he had reasonable            





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