- 23 -
exceed 25 percent). Sec. 6651(a)(1). A taxpayer is excused from
the late-filing addition to tax if he shows that the late filing
was due to reasonable cause and not due to willful neglect. Id.
However, the taxpayer bears the burden of proof on this issue.
Rule 142(a). Petitioner offered no evidence to rebut
respondent’s determination. We sustain respondent’s
determination.
To give effect to our partial allowance of some deductions
petitioner claimed,
Decision will be entered
under Rule 155.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Last modified: May 25, 2011