- 8 - find that excuse for petitioner's failure to file timely his 1991 and 1992 returns to be reasonable cause for purposes of section 6651(a)(1).6 Based on our review of the entire record in this case, we find that petitioner has not satisfied his burden of proving that his failure to file timely his 1991 and 1992 returns was due to reasonable cause and not due to willful neglect. See United States v. Boyle, supra; Estate of Vriniotis v. Commissioner, supra. Accordingly, we find that petitioner is liable for the additions to tax under section 6651(a)(1) for 1991 and 1992.7 To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155. 5(...continued) to file a return and yet will not be liable for the addition to tax under sec. 6651(a)(1). We disagree. 6 Moreover, contrary to the suggestion of petitioner, on the instant record, we find that he had adequate time within which to obtain duplicate copies of, or otherwise to reconstruct, contrac- tor receipts relating to his wife's catering activities. 7 The amounts of such additions to tax, which must take into account the concessions of the parties on other issues, shall be determined by the parties in the Rule 155 computation.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011