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chapter 61 but are contained in chapter 1. Section 1.408-7,
Income Tax Regs., describes reports on distributions from
individual retirement plans. The regulation contains no
requirement that Forms 1099-R be verified by written declaration
under penalties of perjury, and neither the form nor the
instructions contain such a requirement. Therefore, no written
verification by written declaration under penalties of perjury is
required for the form.
Petitioner raised no argument and presented no evidence on
the issue of his liability for the additional tax on early
distributions from qualified retirement accounts.
On this record, we sustain respondent's determinations.
Section 6651(a)(1) Failure To File Timely
For each year in issue, respondent determined that
petitioner is liable for the addition to tax under section
6651(a)(1) for his failure to file timely a Federal income tax
return. Section 6651(a)(1) provides for an addition to tax of 5
percent of the tax required to be shown on the return for each
month or fraction thereof for which there is a failure to file,
not to exceed 25 percent. The addition to tax for failure to
file a return timely will be imposed if a return is not timely
filed unless the taxpayer shows that the delay was due to
reasonable cause and not willful neglect. See sec. 6651(a)(1).
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