- 3 -
Statement of Account
Account Balance Before Examination Action 1$5,083.00CR
Increase in Tax Because of Examination Action 25,008.00
Filing Late Penalty Added 96.00
Interest Charged 158.99
Amount You Now Owe $179.99
1 This amount reflects the $4,700 petitioner paid on April
15, 1996, at the time he filed the extension, and the $383 paid
at time of filing his 1995 return.
2 This amount reflects the tax due reported by petitioner on
his 1995 return.
Petitioner remitted $179.99 to respondent on May 29, 2000
(May 2000 payment). On May 29, 2001, respondent issued
petitioner a notice of deficiency determining a deficiency and an
addition to tax under section 6651(a)(1) for 1995. At trial,
petitioner and respondent agreed to a reduced deficiency of
$4,614 and, as a result, the addition to tax under section
6651(a)(1) was reduced to $1,134.50. Petitioner does not dispute
the amount of the reduced deficiency, and the only issue is
whether he is liable for the reduced addition to tax under
section 6651(a)(1).
Discussion
Section 6651(a)(1) provides in relevant part:
SEC. 6651(a). Addition to the Tax.-–In case of
failure-–
(1) to file any return required * * * on the date
prescribed therefor (determined with regard to any
extension of time for filing), unless it is shown that
such failure is due to reasonable cause and not due to
willful neglect, there shall be added to the amount
required to be shown as tax on such return 5 percent of
the amount of such tax if the failure is for not more
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011