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6651(a)(1). Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438,
447 (2001).
Petitioner requested and was granted two filing extensions,
until August 15, 1999, and then until October 15, 1999, but did
not file his 1998 return until October 15, 2002. Petitioner
provided no evidence that his failure to timely file his 1998 tax
return was due to reasonable cause and not willful neglect. On
this record, we conclude that petitioner is liable for the
addition to tax under section 6651(a)(1), as determined by
respondent.
Contentions we have not addressed are irrelevant, moot, or
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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