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1986 return, which was due to be filed on April 15, 1987, almost 7
years after the records were "scattered". Moreover, petitioner
failed to offer any explanation for his failure to timely file his
1988 Federal income tax return.
Because petitioner has failed to show reasonable cause for the
late filing of either his 1986 or 1988 Federal income tax return,
we sustain respondent's determination of the section 6651(a)(1)
additions to tax.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011