Lola Cowan - Page 6

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            (1985); United States v. Nordbrock, 38 F.3d 440 (9th Cir. 1994).                             
            "Reasonable cause" requires a taxpayer to demonstrate that she                               
            exercised ordinary business care and prudence and was nevertheless                           
            unable to file a return within the prescribed time.  United States                           
            v. Boyle, supra at 246; sec. 301.6651-1(c)(1), Proced. & Admin.                              
            Regs.  Willful neglect means a conscious, intentional failure to                             
            file or reckless indifference.  United States v. Boyle, supra at                             
            245.                                                                                         
                  Petitioner was required to file a Federal income tax return                            
            for 1990.  Sec. 6012.  She failed to do so.  When asked by the                               
            Court whether she had filed tax returns in prior years, petitioner                           
            replied:                                                                                     
                        MS. COWAN:         Years and years ago I did.                                    
                        THE COURT:         And what made you change your                                 
                        mind?                                                                            
                        MS. COWAN:         I believe the things that have                                
                        happened in this country and the way the                                         
                        Government is running things, I just don't                                       
                        agree with it all.                                                               
                        *      *      *      *      *      *      *                                      
                        THE COURT:         * * *  And because you don't                                  
                        agree with what the Government does, you feel                                    
                        you don't have to pay taxes on anything you                                      
                        earn?                                                                            
                        MS. COWAN:         I don't really want to assist                                 
                        them in doing the wrong things in the world.                                     








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