5
Commissioner, 116 T.C. 438 (2001). For the reasons stated
forthwith, we hold that respondent has met this burden.
In the absence of an extension, the last date for petitioner
to file his Federal income tax return for taxable year 2001 was
April 15, 2002. Petitioner testified that he filed an extension
request, but he has been unable to produce any evidence that this
request was sent to the IRS.
Assuming, arguendo, that petitioner had timely submitted an
extension request, an extension would have provided petitioner
until October 15, 2002, to file his 2001 Federal income tax
return. Sec. 6081(a). However, the only bearing a timely
submitted extension request would have had on the instant case
would be in the calculation of the addition to tax. Because we
are unpersuaded that a request for extension of time to file the
return was properly sought, we need not consider a recalculation
of the addition to tax under section 6651(a).
“A failure to file a tax return on the date prescribed leads
to a mandatory penalty unless the taxpayer shows that such
failure was due to reasonable cause and not due to willful
neglect.” McMahan v. Commissioner, 114 F.3d 366, 368 (2d Cir.
1997), affg. T.C. Memo. 1995-547; see sec. 6651(a). A showing of
reasonable cause requires taxpayers to demonstrate that they
exercised “ordinary business care and prudence”, but were
nevertheless unable to file the return within the prescribed
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