Derk O. and Julia K. Pehrson - Page 8

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          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,              





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