Cedric K. and Madelyn D. Nunn - Page 19




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          frivolous tax-protester arguments.  Petitioners are not entitled            
          to deductions for business expenses that are completely                     
          unsubstantiated.  Ronnen v. Commissioner, 90 T.C. 74, 102 (1988).           
               Petitioners have failed to meet their burden of proof with             
          respect to the amounts reported on the Schedules C that were                
          disallowed in the notice of deficiency.  Thus, petitioners are              
          not entitled to any amounts claimed for returns and allowances,             
          cost of goods sold, or business expense deductions reported on              
          the Schedules C for the year at issue.  Respondent is sustained             
          on this issue.                                                              
          4.  Section 6651(a)(1) Addition to Tax                                      
               Respondent determined an addition to tax as a result of                
          petitioners’ failure to timely file their Federal income tax                
          return for the year at issue.  Section 6651(a)(1) imposes an                
          addition to tax for failure to file a timely tax return.  The               
          addition to tax is equal to 5 percent of the amount of the tax              
          required to be shown on the return if the failure to file is not            
          for more than 1 month.  Sec. 6651(a)(1).  An additional 5 percent           
          is imposed for each month or fraction thereof in which the                  
          failure to file continues, to a maximum of 25 percent of the tax.           
          Id.  The addition to tax is imposed on the net amount due.  Sec.            
          6651(b).                                                                    
               The addition to tax is applicable unless a taxpayer                    
          establishes that the failure to file was due to reasonable cause            






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