- 7 -
446-447 (2001). Once respondent has done so, the burden of proof
is upon petitioner to show that respondent’s determination of the
additions is incorrect. See id. at 447.
Petitioner filed his 1999 Federal income tax return on July
6, 2001. That return was due on April 17, 2000. See sec.
6072(a). Accordingly, petitioner filed his 1999 return over a
year late. Also, petitioner failed to pay timely the full amount
of his 1999 liability. Respondent has carried his burden of
production, and petitioner has shown neither reasonable cause nor
a lack of willful neglect for either failure. Therefore, we
sustain the section 6651(a)(1) and (2) additions to tax.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7
Last modified: November 10, 2007