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nor DHF reported any interest income for 1988. We find that
petitioner has not met his burden of proof on this issue. See
Rule 142(a). Therefore, we sustain respondent's determination.
The next issue we must decide is whether petitioner is
liable for additions to tax pursuant to section 6651(a)(1) and
(2). Section 6651(a)(1) imposes an addition to tax for failure
to timely file a tax return, unless the taxpayer establishes that
the failure to file was due to reasonable cause and not willful
neglect. Section 6651(a)(2) imposes an addition to tax for
failure to timely pay a tax liability shown upon a return, unless
the taxpayer establishes that the failure was due to reasonable
cause and not willful neglect.
Petitioner received an automatic extension to file his 1988
return on or before August 15, 1989. Petitioner did not meet
this deadline, as he did not mail his return until September 2,
1989. At the time that he filed, petitioner failed to include
full payment of his reported income tax liability. On brief,
petitioner argues that he had no income tax liability for 1988,
because no liquidation occurred, and petitioner was simply an
agent of FSRC with respect to the sales proceeds reinvested in
LPRC. We have already concluded, however, that a liquidation, in
fact, occurred and that petitioner has income to the extent that
the distribution exceeds the adjusted basis in petitioner's
stock. Moreover, petitioner has not introduced any evidence that
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