Chris E. Columbus - Page 14

                                       - 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 file                       







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011