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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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