- 30 - Respondent determined in her notice of deficiency that petitioner is liable for additions to tax under section 6651(a) in amounts equal to 25 percent of the underpayments for 1983 and 1984. In her answer, respondent conceded that this addition was not due for 1983. On brief, respondent conceded that if we determine that petitioner is not liable for the addition to tax for fraud under section 6653(b) for 1984, then petitioner is liable for no more than a 10-percent addition to the underpayment under section 6651(a). Petitioner offered no proof that he timely filed his return for 1984, or that the late filing was due to reasonable cause and not willful neglect. Petitioner has not carried his burden. We therefore sustain respondent's determination that petitioner is liable for the 10 percent addition to tax under section 6651(a) for 1984. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011