Jeffrey Michael Steingold - Page 6




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          U.S. 456, 465 (1967)).  Although the trust was a simple trust in            
          prior years, in 1994, it was a complex trust.  Accordingly,                 
          petitioner was not required to report the undistributed trust               
          income.                                                                     
          3.   Addition to Tax                                                        
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a required return on the date prescribed, unless such                  
          failure is due to reasonable cause and not willful neglect.                 
          Petitioner failed to present any evidence relating to this issue.           
          Accordingly, respondent’s addition to tax for 1994 is sustained.            
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          





















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