- 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