- 2 - 1988 50,029 12,507 3,198 1989 1,163 291 -- 1990 34,767 8,692 2,290 After concessions by the parties, the only remaining issues are whether petitioner is liable for the additions to tax set forth below: Additions to Tax Year Sec. 6651(a) Sec. 6654 1987 $1,150 $280 1988 611 157 1990 1,186 -- At the time the petition was filed, petitioner resided in Philadelphia, Pennsylvania. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Section 6651(a) imposes an addition to tax for failure to file a tax return in a timely manner. Petitioner's tax returns for 1987, 1988, and 1990 were due on April 15, 1988, 1989, and 1991, respectively. Petitioner, however, did not file such returns until October 10, 1997. Petitioner has failed to establish that her tardiness was due to reasonable cause and not due to willful neglect. Sec. 6651(a); United States v. Boyle, 469 U.S. 241 (1985); Welch v. Helvering, 290 U.S. 111, 115 (1933). Accordingly, petitioner is liable for the section 6651(a) additions to tax.Page: Previous 1 2 3 Next
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