- 16 - said you do not owe the IRS”. Petitioner introduced no other evidence. Petitioner’s explanation was not a legally sufficient reason for his failure to file timely; therefore, the Court finds that petitioner did not have reasonable cause for his failure to file timely. Accordingly, respondent’s determination is sustained. To reflect the foregoing, Decision will be entered for respondent as to the deficiency and the section 6651(a)(1) addition to tax and for petitioner as to the additions to tax under sections 6651(a)(2) and 6654.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17Last modified: March 27, 2008