Hugh Wilkinson and Evelyn Wilkinson - Page 19

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          the accounting firm of Thompson & Co. to prepare, among other                
          things, his Federal income tax returns.  In 1989, Dr. Wilkinson              
          dismissed Thompson & Co. from their accounting duties and hired              
          Frumkin & Lukin to provide accounting services to his medical                
          practice and to prepare tax returns for the years in issue.                  
          These actions demonstrate Dr. Wilkinson's ability to function in             
          his chosen profession, his business acumen, and his ability to               
          exercise ordinary business care and prudence.  Moreover,                     
          petitioners' history of filing untimely returns establishes a                
          pattern of behavior seemingly unrelated to Dr. Wilkinson's                   
          claimed mental illness.                                                      
               We conclude that petitioners are liable for the section                 
          6651(a)(1) addition to tax for 1988 and 1989.  Petitioners failed            
          to file timely tax returns for 1988 and 1989 and have failed to              
          carry their burden of proof on the issues of reasonable cause and            
          willful neglect for those years.                                             
          E.  Failure To Pay Estimated Taxes Under Section 6654                        
               Respondent determined additions to petitioners' 1988 and                
          1989 taxes under section 6654 for underpayment of estimated                  
          Federal income tax.  An addition to tax under section 6654 is                
          mandatory absent the application of one of the exceptions                    
          contained in that section.  Recklitis v. Commissioner, 91 T.C. at            
          913.  We find that none of the exceptions apply; thus, we hold               
          against petitioners on this issue.                                           
          F.  Innocent Spouse Relief                                                   

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