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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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