- 6 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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