George G. Green - Page 38

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          reasonable cause.  See United States v. Boyle, 469 U.S. 241, 245            
          (1985).  To prove reasonable cause, a taxpayer must show that he            
          or she exercised ordinary business care and prudence but                    
          nevertheless could not file the return when it was due.  See                
          Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-            
          1(c)(1), Proced. & Admin. Regs.                                             
               Because petitioner failed to present any explanation as to             
          his late filing, respondent's determination with respect to the             
          addition to tax under section 6651(a)(1) is sustained.                      
               We have considered the arguments of the parties that were              
          not specifically addressed in this opinion.  Those arguments are            
          either without merit or irrelevant to our decision.                         
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             under Rule 155.                          




















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