Lance A. Landers - Page 8

                                        - 7 -                                         
          6651(a)(1).  Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438,            
          447 (2001).                                                                 
               Petitioner requested and was granted two filing extensions,            
          until August 15, 1999, and then until October 15, 1999, but did             
          not file his 1998 return until October 15, 2002.  Petitioner                
          provided no evidence that his failure to timely file his 1998 tax           
          return was due to reasonable cause and not willful neglect.  On             
          this record, we conclude that petitioner is liable for the                  
          addition to tax under section 6651(a)(1), as determined by                  
               Contentions we have not addressed are irrelevant, moot, or             
          without merit.                                                              
               Reviewed and adopted as the report of the Small Tax Case               

                                                  Decision will be entered            
                                             for respondent.                          

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