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$2,181.16, respectively. In addition, petitioner substantiated
$59,242.08 of mortgage interest for 208 Oak Street and is
therefore entitled to deduct $29,621.04.
For 310 Oak Street, petitioner substantiated $81,914.95 of
mortgage interest and $2,057.24 in property taxes and is entitled
to deduct $40,957.48 and $1,028.62, respectively.
Issue 2. Addition to Tax Under Section 6651(a)
Respondent determined an addition to tax under section
6651(a) for delinquent filing of a return.
Section 6651(a) provides that if a taxpayer fails to file a
return by its due date, including extensions of time for filing,
there shall be an addition to tax equal to 5 percent of the tax
required to be shown on the return for each month the failure to
file continues, not to exceed 25 percent. The addition to tax
under section 6651(a) shall not apply, however, if the taxpayer
can show that the failure to timely file the return was due to
reasonable cause and not willful neglect. Sec. 6651(a).
Petitioner did not request an extension of time to file his
1992 Federal income tax return. Petitioner was required to file
a 1992 Federal income tax return by April 15, 1993. Secs. 6012,
6072. Petitioner did not file his 1992 Federal income tax return
until March 28, 1997.
Petitioner testified that he did not file his return until
that time because he could not get the information he needed to
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