- 23 - Petitioner attached a disclosure statement to his 1987 return disclosing significant facts relating to receipt of managed account funds and his involvement with the liquidation of GSC. We reject respondent’s determination of this addition to tax. A taxpayer is subject to an addition to tax for failure to timely file a tax return unless the taxpayer establishes that the failure to timely file was due to reasonable cause and not due to willful neglect. Sec. 6651(a)(1). Petitioner untimely filed his 1987 Federal income tax return on April 4, 1989, without extension. Petitioner failed to present evidence showing reasonable cause. Petitioner is subject to this addition to tax. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
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