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establish that the failures to timely file returns for 1995 and
1998 were due to reasonable cause and not willful neglect.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
7(...continued)
liability for an addition to tax. Further, respondent has the
burden of proof with respect to the increased addition to tax for
1995. Rule 142(a). Respondent has established that the tax
returns for 1995 and 1998 were not timely filed.
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