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Petitioner failed to satisfy the substantiation requirements
of section 274(d) and introduced no receipts for gasoline or
other transportation expenses. The expenses claimed for
transporting crew and materials and for business use of a truck
in 2001 are not deductible.
III. Additions to Tax
Respondent determined additions to tax for failure to file a
tax return, sec. 6651(a)(1), for failure to pay tax reported on a
return, sec. 6651(a)(2), and for failure to pay estimated tax,
sec. 6654(a).
Petitioner routinely hired a tax return preparer. He
claimed that he turned the responsibility for managing the
financial aspects of his business over to Mr. McKinney in 2000.
Petitioner argues that he should not be held liable for the
additions to tax because he relied on Mr. McKinney to prepare and
file his tax returns.
A. Section 6651(a)(1): Failure To File a Tax Return
The parties stipulated that petitioner did not file a
Federal income tax return for 2001 and that he had gross income
of $34,290. His income exceeded the threshold of section
6012(a)(1)(A). Therefore, he had an obligation to file a return.
Respondent made a substitute for return for petitioner under
section 6020(b). A return prepared under section 6020(b) is to
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