- 8 - of willful neglect. As a result, we hold that petitioner is liable for the addition to tax under section 6651(a)(1) for failure to file a timely tax return for the year in issue. In reaching our holding herein, we have considered all arguments made, and, to the extent not mentioned above, we conclude that they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011