- 27 - 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),Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011