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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.
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