Richard and Brenda Nelon - Page 16

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          to that portion of the underpayment resulting from negligence or            
          intentional disregard of rules and regulations.  Negligence is              
          defined as a lack of due care or failure to do what a reasonable            
          and prudent person would do under the circumstances.  Neely v.              
          Commissioner, 85 T.C. 934, 947 (1985).  Petitioner bears the                
          burden of showing that he was not negligent.  Rule 142(a); Bixby            
          v. Commissioner, 58 T.C. 757, 791-792 (1972).                               
               Petitioner did not contend, either at trial or on brief,               
          that his failure to file returns was due to reasonable cause or             
          that his actions were reasonable.  On this record, we find that             
          petitioner is liable for additions to tax for failure to file and           
          negligence for the years indicated above.  In addition, we find             
          that petitioner is liable for additions to tax under section 6654           
          as determined by respondent.                                                
               To reflect the foregoing,                                              
                                             Decision will be entered under           
                                        Rule 155.                                     

















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