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discussed her obligations with her accountant, she put matters
connected with filing her tax return "on the back burner" and
dealt with matters she considered more pressing. See Educational
Fund of Elec. Indus. v. United States, 426 F.2d at 1058; Throop
v. Commissioner, T.C. Memo. 1994-10.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011