- 13 -
shown that the failure to file is due to reasonable cause and not
due to willful neglect.
Petitioners argue that in 1983 petitioner’s father’s death
and a difficult move caused petitioner to become seriously
depressed and provided reasonable cause for petitioners’ failure
to timely file their joint Federal income tax returns for 1985,
1990, and 1991.
Petitioners have failed to establish reasonable cause. Rule
142(a); Welch v. Helvering, supra. Petitioners have not
established that petitioner’s alleged depression constitutes
reasonable cause for their failure to timely file their Federal
income tax returns. Petitioners did timely file applications for
automatic extension of time to file U.S. individual income tax
returns, which shows that petitioners were aware of their tax
obligations. For 1985, 1990, and 1991 petitioners are liable for
the additions to tax under section 6651(a)(1).
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011