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Petitioner did not file Federal income tax returns for any
of the years at issue before issuance of the notice of deficiency
in this case on April 22, 1996. The notice of deficiency was
issued more than a year after April 17, 1995, the latest due date
for petitioner to file any of her Federal income tax returns for
the years at issue in this case.9 Petitioner did not offer any
evidence of reasonable cause for her failure to file.10 Based on
the foregoing, we find that petitioner is liable for the section
6651(a)(1) additions to tax as determined by respondent for each
of the years at issue except 1989.
To reflect the foregoing,
Decision will be entered
under Rule 155.
9 Absent an extension, petitioner’s 1994 Form 1040 was due
on Apr. 17, 1995. In the petition, petitioner avers that she
sought extensions to file her Federal income tax returns for
1992, 1993, and 1994. Respondent admits that petitioner filed
extensions for filing with respect to her 1988, 1989, and 1992
tax years but denies that she filed extensions for her 1993 and
1994 tax years. Petitioner did not present any evidence to
support the claim that she filed or received extensions for any
of the years in question, nor did she present any evidence to
support a finding that any of her returns for the years at issue
in this case were due later than Apr. 17, 1995.
10 As the notice of deficiency in this case was issued on
Apr. 22, 1996, sec. 7491(c) is inapplicable.
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