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Section 6651(a)(1) imposes an addition to tax for a
taxpayer's failure to file a timely return, unless the taxpayer
can establish that such failure "is due to reasonable cause and
not due to willful neglect".
Respondent introduced postmarked envelopes, in which
petitioner's Federal income tax returns for 3 of the 4 years at
issue were mailed, showing that petitioner mailed her 1990
Federal income tax return, the due date for which was April 15,
1991, on November 11, 1991; her 1991 Federal income tax return,
the due date for which was April 15, 1992, on March 3, 1993; and
her 1992 Federal income tax return, the due date for which was
April 15, 1993, on August 17, 1993. Additionally, respondent
introduced official Internal Revenue Service transcripts of
account for petitioner's Federal income taxes (transcripts) for
each of the years at issue, which reflected that petitioner's
1989 Federal income tax return was filed on March 16, 1992, her
1990 Federal income tax return was filed on December 23, 1991,
her 1991 Federal income tax return was filed on March 22, 1993,
and her 1992 Federal income tax return was filed on September 27,
1993. The transcripts also reflected that petitioner had not
requested nor had she been granted a filing extension for any of
the years at issue.
Petitioner contends that she filed timely her 1989 Federal
income tax return but that respondent lost the original return
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