Robert D. Hill - Page 9

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          determination that petitioner is liable for self-employment tax.            
          See Rule 142(a).                                                            
          D.   Addition to Tax and Accuracy-Related Penalty                           
               1.   Addition to Tax                                                   
               Section 6651(a)(1) imposes an addition to tax for failing to           
          file timely a required Federal income tax return, unless it is              
          shown that the failure was due to reasonable cause and not to               
          willful neglect.  Petitioner was required to file a Federal                 
          income tax return for the subject year.  Secs. 6012, 6072.                  
               Respondent met his burden of production as to this addition            
          to tax in that respondent introduced (and the Court admitted)               
          into evidence documentation establishing that petitioner filed              
          his 1999 income tax return untimely.  Petitioner, in turn, has              
          failed to meet his burden of proof.  Petitioner has neither                 
          asserted nor introduced any evidence indicating that he filed his           
          return untimely for cause that is reasonable.  We hold that                 
          petitioner is liable for the addition to tax under section                  
          6651(a)(1).  See United States v. Boyle, 469 U.S. 241, 245                  
          (1985); Cluck v. Commissioner, 105 T.C. 324, 338-339 (1995).                
               2.   Accuracy-Related Penalty                                          
               Section 6662(a) and (b)(1) imposes a penalty equal to 20               
          percent of the amount of an underpayment attributable to                    
          negligence or disregard of rules or regulations.  In this                   
          context, negligence includes any failure to make a reasonable               






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