Thomas Edwards - Page 12




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               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 to             








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