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it provided no details as to the purpose of these costs, other
than that they were incurred in Ghana. Therefore, petitioner’s
documentation did not fulfill the section 274(d) requirements.
Thus, we hold that petitioner is not entitled to any GTG travel,
meal, and entertainment deductions, beyond the $474 allowed by
respondent for 1999, pursuant to section 274(d).
V. Additions to Tax
The parties stipulated that petitioner filed his return for
tax year 1998 on June 21, 2000, his return for tax year 1999 on
February 28, 2001, and his return for tax year 2000 no earlier
than April 14, 2002. Section 6651(a)(1) imposes an addition to
tax for failure to file tax returns on time unless it is shown
that the failure was due to reasonable cause, and not willful
neglect. The stipulation of the parties has met respondent’s
burden of production. Petitioner then bears the burden to show
reasonable cause for late filing. See Marrin v. Commissioner,
147 F.3d 147, 152 (2d Cir. 1998) (“Generally, factors that
constitute ‘reasonable cause’ include unavoidable postal delays,
death or serious illness of the taxpayer or a member of his
immediate family, or reliance on the mistaken legal opinion of a
competent tax adviser, lawyer, or accountant that it was not
necessary to file a return.”), affg. T.C. Memo. 1991-24.
In this case, petitioner offered no testimony or other
evidence that would support his argument that a reasonable cause
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