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addition to tax pursuant to section 6651(a)(1) for 1993. Section
6651(a)(1) imposes an addition to tax for failure to file a
return on the date prescribed (determined with regard to any
extension of time for filing), unless the taxpayer can establish
that such failure is due to reasonable cause and not due to
willful neglect. The taxpayer has the burden of proving the
addition is improper. See Rule 142(a); United States v. Boyle,
469 U.S. 241, 245 (1985).
Petitioner stipulated that he did not file his tax return
for 1993 until August 23, 1995. He offered no evidence showing
that his failure to file was due to reasonable cause and not due
to willful neglect. Accordingly, we hold that petitioner is
liable for the addition to tax pursuant to section 6651(a)(1).
III. Section 6662(a)
Pursuant to section 6662(a), a taxpayer may be liable for a
penalty of 20 percent on the portion of an underpayment of tax
(1) attributable to a substantial understatement of tax or (2)
due to negligence or disregard of rules or regulations. Sec.
6662(b). Whether applied because of a substantial understatement
of tax or negligence or disregard of the rules or regulations,
the accuracy-related penalty is not imposed with respect to any
portion of the understatement as to which the taxpayer acted with
reasonable cause and in good faith. Sec. 6664(c)(1). The
decision as to whether the taxpayer acted with reasonable cause
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