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the year 2000. It was further admitted that petitioner did not
have reasonable cause for the underpayment of his Federal income
tax liability. We therefore hold that petitioner is liable for
an accuracy-related penalty under section 6662(a) for the year
2000 with respect to the portion of the underpayment attributable
to unreported income of $214.16
3. Section 6651(a)(1) Additions to Tax for 2000, 2001, and
2002
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed (determined with regard to
any extension of time for filing) unless the taxpayer can
establish that such failure is because of reasonable cause and
not because of willful neglect.
Petitioner’s Forms 1040, U.S. Individual Income Tax Return,
for 2000, 2001, and 2002 were due to be filed on or before April
15, 2001, 2002, and 2003, respectively. Petitioner’s 2000 and
2001 returns were filed on December 7, 2004, approximately 43 and
31 months late, respectively. Petitioner’s 2002 return was filed
on February 11, 2005, approximately 22 months late. No
extensions were sought from, nor granted, by respondent. It was
deemed admitted under Rule 37(c) that petitioner’s failure to
file his Forms 1040 was due to willful neglect. Furthermore,
petitioner did not have reasonable cause for his failure to file
16Respondent does not seek an accuracy-related penalty under
sec. 6662 for the portion of the underpayment attributable to
petitioner’s unsubstantiated deductions.
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