Gary Wilson - Page 23




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          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.                          





























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Last modified: May 25, 2011