- 4 - At trial, respondent presented a representative of the Connecticut Department of Labor as well as an individual who was controller of Mark in 1993. The witnesses presented records of their respective organizations that supported the amounts determined in the notice of deficiency. Petitioner did not present any evidence to contradict the testimony and documents submitted by respondent supporting the determination. Petitioner asserted that there was continuing corruption, and, therefore, he would not comply with the requirements of filing a return and reporting income. Petitioner has failed to establish that respondent's determination is erroneous. Since there is no question that the unemployment compensation and the wages constitute taxable income, respondent's determination as to the deficiency is sustained. Section 6651(a)(1) provides for an addition to tax for failure to timely file a Federal income tax return. Petitioner was required to file a 1993 Federal income tax return on or before April 15, 1994. Secs. 6012(a), 6072(a). Section 6651(a)(1) further provides that a taxpayer may avoid the addition to tax if the failure to file was due to reasonable cause and not willful neglect. United States v. Boyle, 469 U.S. 241, 245 (1985). We conclude that petitioner's failure to file his 1993 return was due to willful neglect and not due to reasonable cause. Petitioner's unsupported assertions of illegal acts byPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011