-6-
In that petitioner received his nonemployee compensation
from Integrated Business Strategies, Inc., in his capacity as a
nonemployee, we sustain respondent’s determination that
petitioner is liable for self-employment tax on those earnings.
D. Deductions/Exemptions
Taxpayers are required to keep sufficient records to enable
the Commissioner to determine their correct tax liability. Sec.
6001; Menequzzo v. Commissioner, 43 T.C. 824, 831-832 (1965);
sec. 1.6001-1, Income Tax Regs. The record before us does not
contain any documents which would substantiate the allowance of
any deductions and/or exemptions not allowed by respondent. We
sustain respondent’s determination as to this issue.
E. Additions to Tax
1. Section 6651(a)(1)
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 due to
willful neglect. Petitioner was required to file a Federal
income tax return for 1997. Secs. 6012, 6072.3
Respondent met his burden of production in that respondent
introduced (and the Court admitted) into evidence a Form 4340,
Certificate of Assessments, Payments and Other Specified Matters,
3 The minimum amount exception under sec. 6012(a)(1)(A)(i)
does not apply to petitioner, as petitioner’s income exceeded the
minimum amount.
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