James Edward Taylor - Page 6




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          failure to file the return was due to reasonable cause and not              
          due to willful negligence.  See Higbee v. Commissioner, 116 T.C.            
          438, 446 (2001).  The addition to tax under section 6651(a)(1)              
          is, therefore, applicable, and respondent is sustained on that              
          determination.                                                              
                                             Decision will be entered                 
                                        under Rule 155.                               


































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