- 8 - because petitioner husband was incapacitated by a back injury and subsequent surgery. Further, in late 1992, petitioners sold their home and were forced to store their records, as well as other belongings, while they lived temporarily with petitioner husband's parents. Finally, in late 1992 or early 1993, petitioner husband terminated the lease on his office space and had all of his books and records placed in storage. Petitioners contend that their books and records, both business and personal, were inaccessible. Petitioner husband's back injury occurred in 1992, and he underwent surgery in early 1993. Petitioner husband had made sufficient recovery by August 1993 to make a 2-1/2-week cross- country drive by automobile. Moreover, petitioner wife was not physically incapacitated during any of this period. Petitioners' various books and records were placed in storage anywhere from late 1992 to early 1993. The original due date of petitioners' 1993 return was not until April 15, 1994, and petitioners received an additional 6-month extension for the filing of their return. The Court is satisfied that, despite their apparent setbacks, petitioners were afforded an ample amount of time to assemble their books and records and complete their 1993 return. The evidence is insufficient to show that petitioners' failure to timely file a Federal income tax return for 1993 was due to reasonable cause and not due to willful neglect. Petitioners,Page: Previous 1 2 3 4 5 6 7 8 9 Next
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