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loss, petitioner offers only a check and a contractor’s
description of work to be done to install a new driveway. In
support of his medical and dental expenses, petitioner offers a
pay stub showing deductions that are annotated: “PORTION OF GROSS
PAY NOT SUBJECT TO INCOME TAX”.
Respondent concedes that petitioner has substantiated
payments of State and local taxes, real property taxes, personal
property taxes, investment interest expense, and charitable
contributions of $220, $6,799, $166, $922, and $300,
respectively. Our examination of the documents petitioner
provided to substantiate the Schedule A deductions does not allow
us to find that he is entitled to deductions in any greater
amounts. We accept respondent’s concessions and find that
petitioner expended the amounts stated for the purposes stated.
We shall allow the resulting deductions.
II. Additions to Tax
A. Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failing to
file a return on or before the specified filing date (in this
case, April 16, 2001), unless it is shown that this failure is
due to reasonable cause and not due to willful neglect.
Reasonable cause may exist if a taxpayer exercised ordinary
business care and prudence and was nonetheless unable to file the
return by the date prescribed by law. Sec. 301.6651-1(c)(1),
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