- 10 - reliance on an agent, and such reliance is not ‘reasonable cause’ for a late filing under � 6651(a)(1).” Id. at 251-252; see also Cooper v. Commissioner, T.C. Memo. 1997-494; Radabaugh v. Commissioner, T.C. Memo. 1992-572. Given this standard, the failure on the part of petitioner here to ensure that his return was mailed with sufficient postage prepaid and postmarked by the October 15, 1996, due date renders him subject to the section 6651(a) addition to tax. Even if the return was stamped and mailed by the accountant, as petitioner claims, such reliance upon an agent for timely filing would not constitute reasonable cause within the meaning of the statute. Furthermore, nothing in the record supports petitioner’s related contention that Postal Service error is responsible for the untimeliness. Although petitioner asserts that 64 cents was in fact sufficient postage, he did not offer into evidence the actual weight of the original return and envelope. The envelope in which the return was successfully sent bears 78 cents postage affixed by a postal meter. Petitioner has not shown that the return, when weighed by the meter, was not heavy enough to require 78 cents. Section 6662(a) Accuracy-Related Penalty Subsection (a) of section 6662 imposes an accuracy-related penalty in the amount of 20 percent of any underpayment that is attributable to causes specified in subsection (b). SubsectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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