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the sale of property are taxable income and that the deficiencies
determined by respondent are correct.
B. Section 6651(a)(1) Addition to Tax for Failure To File Return
Section 6651(a)(1) provides for an addition to tax in the
case of a failure to file a return on or before the specified
filing date. Section 6651(a)(1) does not apply if the failure to
file is due to reasonable cause and not to willful neglect. Sec.
6651(a)(1); Higbee v. Commissioner, 116 T.C. 438, 447 (2001).
Petitioner bears the “heavy burden” of proving that the failure
to file did not result from willful neglect and that the failure
was due to reasonable cause. United States v. Boyle, 469 U.S.
241, 245 (1985).
Petitioner has not shown that his failure to file was
attributable to reasonable cause; therefore, we sustain the
section 6651(a)(1) additions to tax as determined by respondent.
C. Section 6651(a)(2) Addition to Tax for Failure To Pay Tax
Respondent determined additions to tax for tax years 1996,
1997, and 1998 pursuant to section 6651(a)(2) for failure to pay
tax shown on a return. Section 6651(a)(2) provides:
SEC. 6651. FAILURE TO FILE TAX RETURN OR TO PAY TAX.
(a) Addition to the Tax.--In case of failure--
* * * * * * *
(2) to pay the amount shown as tax on any
return specified in paragraph (1) on or before the
date prescribed for payment of such tax
(determined with regard to any extension of time
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