- 4 -
he or she exercised ordinary business care and prudence but
nevertheless could not file the return when it was due. See
Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-
1(c)(1), Proced. & Admin. Regs. Because petitioner failed to
present any reasonable explanation for his failure to file,
respondent's determination with respect to the addition to tax
under section 6651(a)(1) is sustained.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4
Last modified: May 25, 2011