- 24 - 1993 and 1994. We sustain the disallowance of the balance of the above-listed deductions for lack of substantiation. 4. Section 6651(a)(1) Additions to Tax Section 6651(a)(1) imposes an addition to tax for a taxpayer's failure to file a required return on or before the specified filing date, including extensions. The addition to tax is inapplicable if the taxpayer shows that the failure to file the return was due to reasonable cause and not due to willful neglect. Sec. 6651(a)(1). Generally, individuals are required to file on or before the 15th day of April following the close of the calendar year. Sec. 6072(a). Petitioner filed her 1993 and 1994 Federal income tax returns on July 29, 1994, and July 17, 1995, respectively. According to respondent's records, petitioner did not file an extension of time in which to file her 1993 or 1994 Federal income tax returns. Petitioner contends that she relied upon statements made by her tax preparer, who informed her that extensions for 1993 and 1994 years were filed on her behalf. At trial, petitioner was unable to furnish any evidence showing that extensions for 1993 and 1994 had been filed or any correspondence with a tax return preparer on the subject. Petitioner's failure to make timely filing of her tax returns is not excused by her alleged reliance on an agent, and such reliance is not reasonable cause for a late filing under section 6651(a)(1). United StatesPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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