- 4 -
suffered no detriment that is legally recognizable. He is only
required to pay the tax that was lawfully owing. He did not
change a position to his detriment.
With regard to the late filing addition to tax, section
6651(a)(1) provides for an addition to tax where a return is not
timely filed “unless it is shown that such failure is due to
reasonable cause and not due to willful neglect”. Petitioner
acknowledges that his return was not timely filed. He claims
that he had “so many things going on” that he forgot. This does
not constitute reasonable cause.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4
Last modified: May 25, 2011