- 3 - FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner resided in Dallas, Texas, at the time this petition was filed. Petitioner earned a college degree with a major in banking. He earned his living as a carpenter during the years in issue. Petitioner failed to file U.S. Individual Income Tax Returns for each of the years 1989 through 1995. He asserts that he did not believe he had to file tax returns until he was ordered by a Court to do so. The only source for this alleged belief was "a little bit of studying * * * [with] a group of people who get together in the form of a study group." OPINION Respondent determined that petitioner is liable for the section 6651(a)(1) addition to tax for 1989, 1990, 1991, 1992, and 1993. Section 6651(a)(1) imposes an addition to tax for failure to file a timely return, unless the taxpayer establishes that the failure did not result from "willful neglect" and that the failure was due to "reasonable cause". "Willful neglect" has been interpreted to mean a conscious, intentional failure or reckless indifference. United States v. Boyle, 469 U.S. 241,Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011