- 21 - 4. Laundry Expense With respect to her 1994 tax year, petitioner deducted $596 for professional laundry expense on her Schedule C. Respondent determined that petitioner was entitled to a deduction of $260 for such expense. Petitioner did not introduce evidence supporting a deduction in excess of that determined by respondent. Accordingly, respondent’s determination in this regard is sustained. C. Additions to Tax and Penalties 1. Section 6651(a) Section 6651(a)(1) imposes an addition to tax for failure to timely file a tax return. The addition equals 5 percent of the amount of tax required to be shown on the return for each month the return is late, not to exceed 25 percent in the aggregate. The addition to tax under section 6651(a)(1) is imposed unless the taxpayer establishes that such failure “is due to reasonable cause and not due to willful neglect”. Petitioner failed to timely file her 1992 and 1994 tax returns. She contends that such failure is excusable on the ground that she believed that she had a zero tax liability for each year. Reasonable cause for delinquent filing exists if the taxpayer demonstrates that she exercised ordinary business care and prudence and nonetheless was unable to file the return within the prescribed period. See United States v. Boyle, 469 U.S. 241,Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011