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defined as a “conscious, intentional failure or reckless
indifference.” Id. at 245.
Petitioner’s 1999 return was filed on August 30, 2000.
Having failed to address this issue at trial, petitioner has not
proven he had reasonable cause or a lack of willful neglect.
Therefore, the Court sustains respondent’s determination as to
the section 6651(a)(1) addition to tax.
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