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The evidence demonstrates that petitioner’s 1994 return was
filed well beyond the date it was due. Petitioner did not
explain why her return was filed after the date it was due.
There is nothing in the record that suggests that petitioner’s
failure timely to file her return was due to reasonable cause
and not due to willful neglect. Consequently, we sustain
respondent's determination that she is liable for the addition
to tax under section 6651(a)(1).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011