- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011