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We need not consider other reasons advanced by respondent in
support of the disallowance of the deduction for travel expenses.
Because petitioners are cash basis taxpayers, the expenses
incurred for the trip to Jamaica in January 1999, if otherwise
deductible, are not deductible in 1998. See sec. 461(a).
Accordingly, we sustain respondent’s determination with respect
to the disallowed travel expense deduction.
In the notice of deficiency respondent imposed an addition
to tax under section 6651(a)(1). That section provides for an
addition to tax of 5 percent of the amount of the tax required to
have been shown on the return if the failure to file is for not
more than 1 month, with an additional 5 percent for each month in
which the failure to file continues, to a maximum of 25 percent
of the tax in the aggregate. If an income tax return is not
filed within 60 days of the prescribed date for filing (including
extensions), the addition to tax imposed is not less than the
lesser of $100 or 100 percent of the amount required to be shown
as tax on the return. Sec. 6651(a). The addition to tax is
imposed on the net tax due, sec. 6651(b), and applicable unless
the taxpayer establishes that the failure to file is due to
reasonable cause and not due to willful neglect. Sec.
6651(a)(1); United States v. Boyle, 469 U.S. 241, 245 (1985).
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