- 3 - were self-employment income during the taxable years in which such payments were received. He has also stipulated that respondent properly determined the amounts of his distributive shares of FSC's income, loss, and deductions for the taxable years in issue. The first issue for decision is whether petitioner received and failed to report income during the taxable years in issue. Petitioner has stipulated to all of the adjustments in the statutory notice of deficiency except for the unreported interest income determined from information returns received by respondent. Petitioner has not asserted any reasonable dispute with respect to the accuracy of the information returns. Cf. sec. 6201(d). Based on the record, we find that petitioner has failed to prove any error in respondent's determinations of his unreported income. Rule 142(a). Accordingly, we hold that petitioner received and failed to report income during the taxable years in issue in the amounts determined by respondent. The second issue for decision is whether petitioner is liable for the section 6651(a)(1) additions to tax for failure to file his returns for the taxable years in issue. Section 6651(a)(1) imposes an addition to tax for failure to timely file a return, unless the taxpayer establishes that such failure is due to reasonable cause and not due to willful neglect. "Reasonable cause" requires the taxpayer to demonstrate that he exercised ordinary business care and prudence and wasPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011