Robert A. Fisher - Page 8

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          or incurred during the taxable year.  Although the bank                     
          statements may be taken as substantiation that bank charges were            
          paid, petitioner did not offer any evidence that any part of the            
          bank charges was ordinary and necessary business expenses.                  
          Petitioner's bank accounts appear to be personal in nature, and             
          there is no indication that the accounts were used in a trade or            
          business.  We find that petitioner has not met his burden of                
          proving that bank charges are proper deductions.                            
               Respondent also determined additions to tax under section              
          6651(a)(1) for petitioner's failure to file his 1987 through 1992           
          returns. Section 6651(a)(1) imposes an addition to tax of 5                 
          percent of the amount of the tax due for each month a return is             
          delinquent, up to a maximum of 25 percent.  The addition to tax             
          is not applicable if it is shown that such failure is due to                
          reasonable cause and not willful neglect.  Sec. 6651(a)(1);                 
          United States v. Boyle, 469 U.S. 241, 245 (1985).  Petitioner has           
          the burden of proving that his failure to file was due to                   
          reasonable cause and not willful neglect.  Niedringhaus v.                  
          Commissioner, 99 T.C. 202, 220-221 (1992).                                  
               Petitioner has failed to show that his failure to file                 
          returns for the taxable 1987 through 1992 was due to reasonable             
          cause and not willful neglect.  Petitioner is liable for the                
          additions to tax under section 6651(a)(1) for the taxable years             
          1987 through 1992.                                                          






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