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III. Additions to Tax
Each disqualified person liable for section 4975(a) excise
taxes relating to a prohibited transaction shall file Form 5330
relating to each taxable year, or part thereof, in the taxable
period. See sec. 6011; sec. 54.6011-1(b), Pension Excise Tax
Regs. Section 6651(a)(1) imposes an addition to tax for failure
to file a required return, unless petitioner establishes that
such failure is due to reasonable cause and not willful neglect.
Petitioner failed to file excise tax returns for the years in
issue and has failed to establish that he had reasonable cause
not to file such returns. Accordingly, petitioner is liable for
the section 6651(a)(1) additions to tax.
Contentions we have not addressed are moot, irrelevant, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011