- 38 -
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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