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Petitioner's 1990 Federal income tax return was filed on
October 6, 1992.
Petitioner claims that the 1988 and 1990 Federal income tax
returns were filed late because of difficulties in obtaining
information from an employee of Tek-Pak. At trial, petitioner
asserted that the person whom he hired to run Tek-Pak, an S
corporation of which petitioner was sole shareholder, did not
provide petitioner with all the documents that he needed in order
to file his returns. Petitioner failed to explain, however, what
steps, if any, he took to obtain the records from Tek-Pak. In
any event, he has not established that any difficulty he
encountered in that regard amounts to reasonable cause for the
delinquent filing of the returns. See sec. 301.6651-1(c),
Proced. & Admin. Regs.
Petitioner has failed to show why the additions to tax for
late filing should not apply to him for 1987, 1988, and 1990. We
hold that petitioner is liable for the additions to tax for
failing to timely file his 1987, 1988, and 1990 Federal income
tax returns.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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