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Section 6651(a)(1) imposes an addition to tax for failure to
file a required return on the date prescribed, unless it is shown
that such failure is due to reasonable cause and not willful
neglect. Petitioners have not shown that such failure to file by
the prescribed date was due to reasonable cause and not willful
neglect. Accordingly, petitioners are liable for the section
6651 addition to tax. John Park, however, did not contest
respondent’s determinations relating to a $10,155 income
understatement from a concert promotion business. Thus, the
deficiency and section 6662 penalty concerning this issue are
sustained. Welch v. Helvering, supra at 115.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011