Michael W. Rehtorik, et al. - Page 23

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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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