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There is no evidence in the record that suggests that
petitioner's failure to file timely a Federal income tax return
for any year in issue was due to reasonable cause and not due to
willful neglect. Consequently, we sustain respondent's
determination that petitioner is liable for the additions to tax
under section 6651(a)(1) for the years 1994 through 1996.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011