- 5 - failure to file the return was due to reasonable cause and not due to willful negligence. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). The addition to tax under section 6651(a)(1) is, therefore, applicable, and respondent is sustained on that determination. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6Last modified: November 10, 2007