Robert C. Geib - Page 7




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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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