- 16 -
argument regarding the claimed $600,000 bad debt deduction and
other alternative arguments.
With respect to the addition to tax under section 6651(a)(1)
for petitioner's failure to timely file its 1989 corporate
Federal income tax return and the computation of that addition to
tax, we hold for respondent. Petitioner has offered no evidence
to establish reasonable cause for its failure to timely file its
1989 corporate Federal income tax return nor any evidence to
establish that the $60,000 estimated tax payment was made on
May 15, 1989, the due date of the estimated tax payment for
purposes of computing the amount of the addition to tax under
section 6651(a)(1). We sustain respondent on these issues.
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011