- 15 - a 9-day trip to Hawaii in March 1985.6 At trial, Mr. Kerrigan testified that this was a business trip for both him and Mrs. Kerrigan. However, Mrs. Kerrigan did not record in her log the business purpose of the trip or any meetings she had there. Moreover, there was no testimony presented at trial indicating that Mrs. Kerrigan ever worked outside of suburban Maryland in 1985. Mr. Kerrigan also claimed a Schedule C travel and entertainment expense deduction of $12,409.69. Respondent allowed a deduction of $5,296. Mr. Kerrigan failed to substantiate any deductions for travel and entertainment in excess of the amount already allowed by respondent. Section 6651(a) Section 6651(a) imposes an addition to tax for failure to file a timely return. Sec. 6651(a)(1). Respondent's determination is presumed correct, and petitioners bear the burden of proving otherwise. Rule 142(a); Abramo v. Commissioner, 78 T.C. 154, 163 (1982). Section 6651(a) provides an exception when the taxpayer's failure to file is due to reasonable cause and not willful neglect. Petitioners make no argument that there was reasonable cause for their nearly 3-year delay in filing. Instead, they argue that no deficiency exists, 6Petitioners did not allocate any portion of their travel expenses as personal expenditures.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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