David Furniss - Page 6




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          Business, deductions for the years in issue.5  Petitioner has the           
          burden of proof on this issue.  See Rule 142(a).  We allowed                
          petitioner ample time to present evidence establishing these                
          deductions.  Petitioner failed to introduce any such evidence or            
          even indicate the specific deductions to which he believed he was           
          entitled.  We hold that petitioner failed to carry his burden of            
          proof.  See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84                  
          (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                
          (1934); Wichita Terminal Elevator Co. v. Commissioner, 6 T.C.               
          1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947).                     
          Petitioner is not entitled to any Schedules A or C deductions for           
          the years in issue.                                                         
          III.  Section 6651(a)(1) Addition to Tax                                    
               Section 6651(a)(1) authorizes the imposition of an addition            
          to tax for failure to file a timely return, unless it is shown              
          that such failure is due to reasonable cause and not due to                 
          willful neglect.  See sec. 6651(a)(1); United States v. Boyle,              
          469 U.S. 241, 245 (1985); United States v. Nordbrock, 38 F.3d               
          440, 444 (9th Cir. 1994); Harris v. Commissioner, T.C. Memo.                
          1998-332.                                                                   



               5Petitioner also asserted he was entitled to Schedule B,               
          Interest and Ordinary Dividends, deductions for the years at                
          issue.  Schedule B is a form used to report the taxpayer’s                  
          receipt of interest and ordinary dividends.  There are no                   
          Schedule B deductions; therefore, petitioner is not entitled to             
          any such deduction.                                                         





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