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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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Last modified: March 27, 2008