- 4 - however, to offer any evidence (e.g., a police report or insurance claim) to establish his contention. Petitioner also contends that in 1994 two of his automobiles were stolen. He has failed, however, to offer any evidence relating to their cost. In addition, he has failed to establish that the allegedly stolen automobiles were not compensated for by insurance. We conclude that petitioner is not entitled to a casualty loss deduction and that respondent's deficiency determinations, adjusted for concessions, are correct. Respondent determined that petitioner is liable, pursuant to section 6651(a)(1), for failure to file his 1993 and 1994 Federal income tax returns. Section 6651 imposes an addition to tax for failure to file a tax return in a timely manner, unless such failure was due to reasonable cause and not due to willful neglect. Petitioner has the burden of proving that he is not liable for the additions to tax. Rule 142(a); see Welch v. Helvering, 290 U.S. 111, 115 (1933). He contends that he filed his returns and, therefore, is not liable for the additions to tax. The Internal Revenue Service has no record that it received such returns, and petitioner failed to present either copies of his returns or mailing receipts. We conclude that petitioner has failed to establish that he filed his 1993 and 1994 returns. Accordingly, he is liable for the section 6651(a)(1) additions to tax.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011