10 for those purposes. Petitioner paid expenses not associated with the activity, such as her insurance premiums, from the account. Petitioner had no business records for the activity. Petitioner had no expertise in providing tours, nor did she have any special knowledge of Haiti. Petitioner did not devote much of her time to Too Close To Home. She worked 80 hours a week in her jobs and carried on Too Close to Home during lunch and between jobs. Petitioner did not carry on Too Close To Home for profit during the year in issue. Therefore, her deductions are limited to the income derived from the activity, which was zero. Petitioner offered no evidence to support a deduction for State and local income taxes. Therefore, she is not entitled to a deduction. Respondent determined an addition to tax as a result of petitioner's failure to file a timely return. Section 6651(a)(1) imposes an addition to tax for failure to file a timely tax return. The addition to tax is equal to 5 percent of the amount of the tax required to be shown on the return if the failure to file is not more than 1 month. Sec. 6651(a)(1). An additional 5 percent is imposed for each month or fraction thereof in which the failure to file continues, to a maximum of 25 percent of the tax. Id. The addition to tax is applicable unless petitioner establishes that the failure to file was due to reasonable cause and not willful neglect. Id. Petitioner's 1989 return was received by respondent on September 1, 1995. Petitioner offered no testimony or evidencePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011