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taxpayer can establish that such failure is due to reasonable
cause and not due to willful neglect. Petitioner did not timely
pay her taxes for 2003. Petitioner did not present any evidence
indicating that her failure to timely pay her taxes was due to
reasonable cause and not due to willful neglect. Accordingly, we
hold that petitioner is liable for the addition to tax under
section 6651(a)(2).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007