- 10 - with reference to checking account information from 1992 must be eliminated from respondent’s computation. Depreciation Deductions Petitioners have failed to offer any evidence to contradict respondent’s partial disallowance of their depreciation deductions. Petitioner suggested he had depreciation schedules that would support the allowance of those deductions and was given ample time following trial to provide these schedules, but he failed to do so. Respondent is sustained on this issue. Charitable Contribution Deductions Respondent disallowed the charitable contribution deduction petitioners claimed for each year in issue. The revenue agent testified that she did not question those deductions during the examination of petitioners’ returns. Furthermore, the deductions were taken into account in respondent’s cash T-account analysis. On the basis of petitioner’s testimony, we find that petitioners are entitled to the charitable contribution deductions as claimed on their returns. Section 6651 Addition to Tax The failure to file a timely Federal income tax return results in a mandatory addition to tax unless the taxpayer shows that the failure was due to reasonable cause and not due to willful neglect. Sec. 6651(a). The taxpayer bears the heavy burden of proving both of these elements. United States v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011