- 14 - Fifth, petitioner argues that he is not liable for the addition to tax for failure to file a timely return as provided by section 6651(a)(1) because his failure to file each of the subject tax returns was due to reasonable cause. He claims that he did not file those tax returns because he was uncertain about whether he could claim his oldest daughter as a dependent and he wanted to "call attention" to himself. At trial, petitioner stated as follows: Q Is there any reason that you did not file your returns, other than your uncertainty about the -- whether your oldest daughter Angie, was a dependent or not? Is that the only reason? A No. The other reason was to call attention on myself. Q You thought that would get you noticed by the IRS? A I thought it would lead to answers. Section 6651(a)(1) provides that if a taxpayer fails to file a tax return on the date prescribed for filing, including any extension of time for filing, an addition to tax in an amount equal to 5 percent of the tax required to be shown on the return will be imposed for each month, or fraction thereof, during which the failure to filePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011