- 27 -
Petitioner testified that, in the year 2000, the water filters
became inoperable and thus were of no value.
Respondent contends that petitioner provided no
documentation to show that he purchased, utilized, and disposed
of the water filter inventory. Respondent further contends that
petitioner’s Schedule C for petitioner’s 1989 tax year standing
alone is insufficient to demonstrate that petitioner was in a
business activity for the sale of environmental equipment.
Respondent further argues that there is no proof that petitioner
filed a return for 1989.
The record does not show that petitioner either purchased or
held a water filter inventory and, if he did, what was the cost
of that inventory. The Court rejects petitioner’s entitlement to
a deduction on this issue.
The Court next addresses the addition to tax under section
6651(a)(1) for failure to file a timely 2000 income tax return.
Section 6651(a)(1) provides for an addition to tax for
failure to file a timely Federal income tax return unless the
taxpayer shows that such failure was due to reasonable cause and
not willful neglect. United States v. Boyle, 469 U.S. 241, 245
(1985); Baldwin v. Commissioner, 84 T.C. 859, 870 (1985); Davis
v. Commissioner, 81 T.C. 806, 820 (1983), affd. without published
opinion 767 F.2d 931 (9th Cir. 1985).
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011