- 66 - determinations that this addition to tax should be imposed against him. Funk v. Commissioner, 687 F.2d 264, 266 (8th Cir. 1982), affg. T.C. Memo. 1981-506; Ehrlich v. Commissioner, 31 T.C. 536, 540 (1958). Petitioner filed his 1983 through 1986 tax returns late. See supra, note 2 and table 2. Petitioner has not shown that his failure to timely file these returns was due to reasonable cause. Petitioner has failed to carry his burden of proof. We hold for respondent on this issue. B. Section 6653(a) Section 6653(a)(1)20 (sec. 6653(a)(1)(A), as to 1986) 20Sec. 6653(a), as in effect for 1983 through 1985, provides, in pertinent part, as follows: SEC. 6653. FAILURE TO PAY TAX. (a) Negligence or Intentional Disregard of Rules and Regulations with Respect to Income, Gift, or Windfall Profit Taxes.-- (1) In general.--If any part of any underpayment (as defined in subsection (c)(1)) of any tax imposed by subtitle A * * * is due to negligence or intentional disregard of rules or regulations (but without intent to defraud), there shall be added to the tax an amount equal to 5 percent of the underpayment. (2) Additional amount for portion attributable to negligence, etc.--There shall be added to the tax (in addition to the amount determined under paragraph (1)) an amount equal to 50 percent of the interest payable under section 6601-- (continued...)Page: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 Next
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