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petitioner’s failure to substantiate the expenses as required
under section 274(d), respondent’s disallowance of car and truck
expense deductions is sustained in all respects.
Respondent contends that petitioner is liable for additions
to tax pursuant to section 6651(a)(1). Section 6651(a)(1)
imposes an addition to tax for failure to file a Federal income
tax return by its due date, determined with regard to any
extension of time for filing previously granted. The addition
equals 5 percent for each month that the return is late, not to
exceed 25 percent. Sec. 6651(a)(1).
Additions to tax under section 6651(a)(1) are imposed unless
the taxpayer establishes that the failure was due to reasonable
cause and not willful neglect. Sec. 6651(a)(1). The taxpayer
must prove both reasonable cause and a lack of willful neglect.
Crocker v. Commissioner, 92 T.C. 899, 912 (1989). "Reasonable
cause" requires the taxpayer to demonstrate that he exercised
ordinary business care and prudence. United States v. Boyle, 469
U.S. 241, 246 (1985). Willful neglect is defined as a
"conscious, intentional failure or reckless indifference." Id.
at 245.
Petitioner filed his 1993 return on September 16, 1996, and
his 1995 return on December 29, 1997. Respondent established
that the returns were not filed by their due date. Petitioner
made no argument and presented no evidence to show that his
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