- 9 - information to the Court. He did not. For all of the foregoing reasons, we conclude that petitioner is not entitled to a deduction in the amount of $1,320 for a theft loss.3 Section 6651(a)(1) Addition to Tax As of the time of trial, petitioner had not filed his 2000 Federal income tax return. Petitioner testified that he gave his 2000 return to a U.S. Postal Service employee at the 30th Street Post Office Station in Philadelphia, Pennsylvania, on the evening of April 15, 2001. Respondent’s records, however, indicate that petitioner requested an extension to file until August 15, 2001, and to date, petitioner has not filed his return. On the instant record, we find that petitioner has failed to satisfy his burden of proving that his failure to file timely his return for 2000 was due to reasonable cause and not willful neglect. Sec. 6651(a). Accordingly, we sustain respondent's determination imposing the addition to tax under section 6651(a)(1) for taxable year 2000. 3 Even if we did allow the petitioner a theft loss deduction of $1,320, petitioner’s standard deduction for 2000 would be greater than the loss allowed. Accordingly, it is of no tax consequence to petitioner that we sustain respondent on this issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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