Douglas Michael Riley - Page 6

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          fraction thereof during which the failure to file continues, up             
          to a maximum of 25 percent.  See sec. 6651(a)(1).                           
               The parties have stipulated that respondent received the               
          returns for each of the years in issue on December 16, 1996.                
          This was more than 5 months after the due dates, including any              
          extensions available to petitioner pursuant to section 6081(a),             
          for the returns for taxable years 1992, 1993, and 1994.  With               
          respect to the 1995 taxable year, respondent has no record                  
          indicating that petitioner was granted an extension of time to              
          file for that year, and petitioner has offered no evidence with             
          respect to any extension.  Accordingly, we conclude that the 1995           
          return was filed more than 5 months after its due date.                     
          Petitioner has offered no evidence of reasonable cause.                     
          Therefore, petitioner is liable for section 6651(a)(1) additions            
          to tax equal to 25 percent of the amount of the tax required to             
          be shown on the return for each of the years in issue.                      
          3.  Accuracy-Related Penalties Under Section 6662                           
               Petitioner bears the burden of proving that the                        
          determinations pursuant to section 6662(a) are erroneous.  See              
          Rule 142(a).  Petitioner has introduced no evidence relating to             
          these determinations.  Therefore, he is liable for accuracy-                
          related penalties under section 6662(a).                                    

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