- 11 - vague and conclusory and does not even address the specifics of his duties in that year. We conclude that he has failed to demonstrate error in respondent's determinations of liability for self-employment tax in 1987 and 1989 and accordingly sustain them. Additions to Tax Under Section 6651(a)(1) Respondent determined additions to tax for failure to timely file returns under section 6651(a)(1) with respect to both years in issue. Petitioner claims that his failure to file for these years was due to reasonable cause. Section 6651(a)(1) imposes an addition to tax for failure to timely file a return unless it is shown that such failure is due to reasonable cause and not due to willful neglect. The amount of the addition to tax is determined on a graduated basis, beginning at the rate of 5 percent of the amount required to be shown on the return if the failure is not more than 1 month, with an additional 5 percent for each additional month or fraction thereof that such failure continues, not exceeding 25 percent in the aggregate. Sec. 6651(a)(1). To prove reasonable cause, a taxpayer must show that he exercised ordinary business care and prudence but nevertheless was unable to file the return when it was due. Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Petitioner argues that he had reasonablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011