- 13 - Mr. McKinney’s failure to meet petitioner’s expectations with respect to preparing and filing petitioner’s tax return does not excuse petitioner’s failure to file his own tax return. Because petitioner has failed to offer satisfactory evidence of reasonable cause and lack of willful neglect for his failure to file, respondent’s determination that he is liable for the addition to tax under section 6651(a)(1) is sustained. B. Section 6651(a)(2): Failure To Pay Amount Shown as Tax Respondent has met his burden of production under section 7491(c) with respect to imposing the addition to tax under section 6651(a)(2) because the record clearly reflects that petitioner did not pay the amount shown as due on a tax return.6 As with petitioner’s failure to file, discussed above, petitioner’s reliance on Mr. McKinney does not excuse petitioner’s failure to pay the tax due for 2001. Petitioner failed to offer sufficient evidence of reasonable cause and lack of willful neglect for his failure to pay the tax due for 2001. Accordingly, respondent’s determination that petitioner is liable for the addition to tax under section 6651(a)(2) is sustained. 6 Under sec. 6651(g)(2), the substitute for return is to be treated as a return filed by petitioner for purposes of determining the amount of the addition to tax under sec. 6651(a)(2).Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007