- 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 unablePage: Previous 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 Next
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