Howard K. Hager - Page 17




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          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.                          
























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