- 14 - 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 causePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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