- 5 - v. Commissioner, 788 F.2d 1406, 1408 (9th Cir. 1986), affg. T.C. Memo. 1984-533; Kennelly v. Commissioner, 56 T.C. 936, 943 (1971), affd. 29 AFTR 2d 72-855, 72-1 USTC par. 9348 (2d Cir. 1972). Due to petitioner’s failure to request available reimbursement for his employee business expenses, petitioner is not entitled to deduct them. See Orvis v. Commissioner, supra at 1408; Kennelly v. Commissioner, supra at 943. Petitioner is liable for the deficiencies in income tax determined by respondent for the years in issue. Petitioner’s argument that he failed to file Federal income tax returns and to pay tax for the years in issue because of his purported belief that wage and investment income does not constitute taxable income is frivolous. Petitioner has offered no credible evidence showing that his failure to file Federal income tax returns and to pay estimated tax was due to reasonable cause. We sustain respondent’s determination of the section 6651(a)(1) addition to tax and the section 6654(a) addition to tax. Under section 6651(a)(2), an addition to tax may be imposed on a taxpayer for failure to pay any Federal income tax reflected as due on a tax return. Petitioner failed to file Federal income tax returns for the years in issue, and respondent has not asserted that respondent prepared substitute tax returns forPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011