AJF Transportation Consultants, Inc. - Page 33




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                    In this case, AJF neglected to retrieve its tax returns from                                  
             its return preparer, Witkowski, and timely file them with                                            
             respondent.  Therefore, we find that AJF's untimely filing of its                                    
             returns was not due to reasonable cause.  Accordingly, we sustain                                    
             respondent's determination with respect to the additions to tax                                      
             imposed by section 6651(a) for AJF's 1988, 1989, and 1990 taxable                                    
             years.                                                                                               
                    Contentions not addressed are either irrelevant or without                                    
             merit.                                                                                               
                    To reflect the foregoing,                                                                     
                                                            Decisions will be entered                             
                                                     under Rule 155.                                              


























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Last modified: May 25, 2011