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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
filings.
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,
letter.
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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Last modified: May 25, 2011