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be filed by all individuals receiving gross income in excess of
certain minimum amounts. See sec. 6012; sec. 1.6012-1(a), Income
Tax Regs. For the years 1989 through 1994, petitioners' gross
income, as defined in section 61(a), was well in excess of the
minimum amounts specified in section 6012. Therefore,
petitioners were required to file Federal income tax returns for
the years 1989 through 1994. See secs. 6011, 6012(a)(1)(A),
7701(a)(1); sec. 1.6012-1(a), Income Tax Regs.
Section 6651(a) imposes an addition to tax for failure to
file timely a return, unless the taxpayer establishes: (1) The
failure did not result from willful neglect, and (2) the failure
was due to reasonable cause. See United States v. Boyle, 469
U.S. 241, 245-246 (1985). Petitioners bear the burden of proof
on this issue. See Rule 142(a); Baldwin v. Commissioner, 84 T.C.
859, 870 (1985). Petitioners failed to prove reasonable cause
for their failure to file. Accordingly, petitioners are liable
for additions to tax for failure to file returns under section
6651(a) for the years 1989 through 1994.
Issue 4. Failure To Pay Estimated Income Tax
Respondent determined that petitioners were liable for the
addition to tax under section 6654(a) for failure to pay
estimated tax for the years 1989 through 1994. Where payments of
tax, either through withholding or by making estimated quarterly
tax payments during the course of the year, do not equal the
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