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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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Last modified: May 25, 2011