- 11 - Petitioner failed to satisfy the substantiation requirements of section 274(d) and introduced no receipts for gasoline or other transportation expenses. The expenses claimed for transporting crew and materials and for business use of a truck in 2001 are not deductible. III. Additions to Tax Respondent determined additions to tax for failure to file a tax return, sec. 6651(a)(1), for failure to pay tax reported on a return, sec. 6651(a)(2), and for failure to pay estimated tax, sec. 6654(a). Petitioner routinely hired a tax return preparer. He claimed that he turned the responsibility for managing the financial aspects of his business over to Mr. McKinney in 2000. Petitioner argues that he should not be held liable for the additions to tax because he relied on Mr. McKinney to prepare and file his tax returns. A. Section 6651(a)(1): Failure To File a Tax Return The parties stipulated that petitioner did not file a Federal income tax return for 2001 and that he had gross income of $34,290. His income exceeded the threshold of section 6012(a)(1)(A). Therefore, he had an obligation to file a return. Respondent made a substitute for return for petitioner under section 6020(b). A return prepared under section 6020(b) is toPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007