- 12 - intentional failure or reckless indifference to the obligation to file. See United States v. Boyle, supra. Petitioner filed his 1994 tax return on May 3, 1996. Petitioner has not provided any explanation for the late filing of the return. Petitioner has not addressed the issue in his pleadings or his testimony. Petitioner has not established his late filing of his 1994 Federal income tax return was due to reasonable cause and not willful neglect. Accordingly, we hold petitioner is liable for the addition to tax under section 6651(a). We have considered all of petitioner's arguments and, to the extent not discussed above, find them to be without merit.4 To reflect the foregoing, Decision will be entered for respondent. 4 Petitioner asserts that respondent has wrongfully assessed and levied Federal and District of Columbia tax refunds granted for the 1997 tax year, while he is a petitioner before this Court. The record before us demonstrates the levy was applied to petitioner's assessed tax liabilities for tax year 1993, a year not before us.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011