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Issue 4. Addition to Tax Pursuant to Section 6651
Respondent determined that petitioners' return was filed 1
day late. Section 6651 imposes an addition to tax for failure to
file a timely tax return, unless such failure was due to
reasonable cause and not due to willful neglect. Petitioners
neither argued nor offered any evidence to show that the addition
to tax pursuant to section 6651 should not be imposed.
Therefore, we sustain respondent's determination that the
addition to tax is applicable.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011