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to the respective due dates of those returns, petitioner was
aware of those due dates and knew that he had a duty to file
timely those returns. The record discloses no valid reason why
petitioner, with the assistance of his accountant Mr. Todar,
could not have prepared and timely filed his 1991 and 1992
returns on the basis of the information that petitioner had
available at the time those returns were due. Thereafter,
petitioner could have filed amended returns in order to reflect
any additional information that he obtained regarding his wife's
catering activities. See Estate of Vriniotis v. Commissioner, 79
T.C. 298, 311 (1982); Beck Chemical Equip. Corp. v. Commissioner,
27 T.C. 840, 859-860 (1957).
Indeed, Mr. Todar testified that he could have prepared
petitioner's 1991 and 1992 returns on the basis of the informa-
tion that petitioner provided to him and that those returns could
have thereafter been amended in the event that petitioner gave
him additional information relating to his wife's catering
activities. While Mr. Todar also testified that any such returns
would not have been complete, and therefore would not have been
accurate, because not all of the information relating to the
catering activities of petitioner's wife was available at the
time those returns were due,5 on the present record, we do not
5 Under petitioner's position, as long as a taxpayer did not
have all of the information that was needed to prepare a com-
plete, and therefore accurate, return, he or she will never have
(continued...)
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