Sherif S. Abdelhak a.k.a. Samuel A. Abel - Page 14

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          it provided no details as to the purpose of these costs, other              
          than that they were incurred in Ghana.  Therefore, petitioner’s             
          documentation did not fulfill the section 274(d) requirements.              
          Thus, we hold that petitioner is not entitled to any GTG travel,            
          meal, and entertainment deductions, beyond the $474 allowed by              
          respondent for 1999, pursuant to section 274(d).                            
          V.  Additions to Tax                                                        
               The parties stipulated that petitioner filed his return for            
          tax year 1998 on June 21, 2000, his return for tax year 1999 on             
          February 28, 2001, and his return for tax year 2000 no earlier              
          than April 14, 2002.  Section 6651(a)(1) imposes an addition to             
          tax for failure to file tax returns on time unless it is shown              
          that the failure was due to reasonable cause, and not willful               
          neglect.  The stipulation of the parties has met respondent’s               
          burden of production.  Petitioner then bears the burden to show             
          reasonable cause for late filing.  See Marrin v. Commissioner,              
          147 F.3d 147, 152 (2d Cir. 1998) (“Generally, factors that                  
          constitute ‘reasonable cause’ include unavoidable postal delays,            
          death or serious illness of the taxpayer or a member of his                 
          immediate family, or reliance on the mistaken legal opinion of a            
          competent tax adviser, lawyer, or accountant that it was not                
          necessary to file a return.”), affg. T.C. Memo. 1991-24.                    
               In this case, petitioner offered no testimony or other                 
          evidence that would support his argument that a reasonable cause            






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