- 11 -
Boyle, 469 U.S. 241, 246 (1985). "Willful neglect" is defined as
a "conscious, intentional failure or reckless indifference." Id.
at 245.
Petitioner agrees that he did not timely submit his Federal
income tax returns for 1998, 1999, or 2000. Respondent has met
his burden of production regarding petitioner's liability for the
additions to tax. Petitioner did not provide any evidence that
would demonstrate that he had reasonable cause or lacked willful
neglect in failing to timely file his returns. Respondent's
determination as to the section 6651(a)(1) additions to tax is
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011