- 8 -
addition to tax under section 6651(a). Petitioner did not
explain why his 1996 return was filed late. Because petitioner
has not demonstrated that his failure to file a timely 1996
Federal income tax return was due to reasonable cause and not due
to willful neglect, he is liable for the addition to tax under
section 6651(a)(1) as determined by respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
Based on the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011