Joseph S. King - Page 4

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            Utah, Service Center on July 27, 1987.  The return was due to be                          
            filed on or before April 15, 1987.                                                        
                  3.  Respondent reviewed the administrative file for each                            
            taxable year in issue.  The files contain no extensions of time                           
            for filing of a Federal income tax return, nor are there any                              
            explanations from petitioner as to reasonable cause for late                              
                  4.  Respondent reviewed the transcripts of account for each                         
            taxable year in issue.  The transcripts of account revealed that                          
            no extensions of time for filing of Federal income tax returns                            
            were sought or granted.                                                                   
                  5.  In the preparation of this case for trial, respondent                           
            requested, in a letter dated May 20, 1997, that petitioner                                
            provide respondent with a written statement explaining why the                            
            addition to tax for late filing under section 6651(a) would not                           
            be applicable if petitioner chose not to concede the issue.                               
                  6.  Petitioner did not answer respondent’s May 20, 1997,                            
                  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.  An                               
            additional 5 percent is imposed for each month or fraction                                
            thereof in which the failure to file continues, to a maximum of                           

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