William M. Leggett - Page 8

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          evidence regarding reasonable cause or substantial authority.               
          Higbee v. Commissioner, supra at 446-447.                                   
               A.   Section 6651(a)(1)                                                
               Respondent determined that petitioner is liable for an                 
          addition to tax pursuant to section 6651(a)(1) for 2001.  Section           
          6651(a)(1) imposes an addition to tax for failure to file a                 
          return on the date prescribed (determined with regard to any                
          extension of time for filing), unless such failure is due to                
          reasonable cause and not due to willful neglect.                            
               Petitioner did not file a return for 2001.  Accordingly,               
          respondent has met his burden of production for the section                 
          6651(a)(1) addition to tax for 2001.                                        
               Petitioner has not established that his failure to timely              
          file for 2001 was due to reasonable cause.  See Higbee v.                   
          Commissioner, supra at 446-447.  Accordingly, petitioner is                 
          liable for the section 6651(a)(1) addition to tax for 2001.                 
               B.   Section 6654(a)                                                   
               Section 6654 imposes an addition to tax for failure to pay             
          estimated income tax.  Respondent submitted no evidence that                
          petitioner failed to pay estimated tax for 2001.  Furthermore,              
          the stipulations do not establish that petitioner failed to pay             
          estimated tax for 2001.  Accordingly, we conclude that respondent           
          has not satisfied his burden of production regarding this issue             







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