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The record does not show that petitioner had good tax return
filing habits. Petitioner habitually filed his Federal income
tax returns late. He had extensions of time to file his returns
for 1991, 1992, 1993, 1994, 1995, and 1996, but did not file them
until after the extended time had passed. As of the date of
trial, petitioner had not filed his returns for 1994, 1995, and
1996.
Petitioner contends that Ball had valid reasons for not
preparing petitioner's returns for 1994, 1995, and 1996. We
disagree. Ball's explanations were vague and unsatisfactory.
Ball attributed the delay to his health problems. However, he
testified that others in his office could prepare petitioner's
returns. Ball testified that petitioner's claim for a refund was
a problem on petitioner's 1994 return. However, Ball testified
that he eventually decided to prepare a return for petitioner for
1994 without applying for the refund. Ball testified that he
wanted petitioner to claim a loss on petitioner's 1995 return
under section 1244 related to a liquor store. However,
petitioner kept no records for the store. Ball said that he had
all of the data required for petitioner's 1996 return before
April 15, 1997. Ball's testimony does not convince us that
petitioner had valid reasons for not filing his 1994, 1995, and
1996 returns.
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