7
percent of the tax. The addition to tax is applicable unless it
is established that the failure to file is due to reasonable
cause and not due to willful neglect. Sec. 6651(a)(1).
Petitioner bears the burden of establishing that he is not liable
for this addition to tax. Rule 142(a).
Petitioner filed his 1989 Federal income tax return on
February 4, 1991, almost 1 year after the return was due. He
filed no requests for extensions and presented no evidence as to
why the return was untimely. Therefore, we sustain respondent on
this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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