Juanita Carter - Page 20

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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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