Inverworld, Inc., et al. - Page 157

                                                - 233 -                                                   
                        b.  we hold that Holdings is not entitled to claimed                              
            deductions for professional and legal fees for its taxable years                              
            ended 1988 and 1989;                                                                          
                        c.  we hold that Holdings is not entitled to deductions                           
            claimed for employee training and recruiting for its taxable year                             
            ended 1989;                                                                                   
                        d.  we hold that Holdings is liable for the                                       
            environmental tax pursuant to section 59A.                                                    
            G.    Additions to Tax                                                                        
                  Respondent determined in notices of deficiency that                                     
            petitioners are liable for (1) the additions to tax imposed by                                
            section 6651(a)(1) for failure to file timely income or                                       
            withholding tax returns, (2) the additions to tax imposed by                                  
            section 6653(a) for negligence or disregard of rules or                                       
            regulations, (3) the additions to tax imposed by section 6655(a)                              
            for failure to pay estimated tax, (4) the additions to tax                                    
            imposed by section 6656(a) for failure to make timely deposits of                             
            taxes, and (5) the additions to tax imposed by section 6661(a)                                
            for substantial understatement of income tax.  We shall examine                               
            the additions to tax separately.                                                              
                  1.    Section 6651(a)(1)                                                                
                  Section 6651(a)(1) imposes an addition to tax for failure to                            
            file timely a tax return unless it is shown that such failure is                              
            due to reasonable cause and not willful neglect.  A taxpayer can                              
            establish reasonable cause by showing that, despite the exercise                              
            of ordinary business care and prudence, the taxpayer was unable                               




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