Judith Weingarth Fox - Page 2

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          1988           50,029           12,507            3,198                     
          1989            1,163              291              --                      
          1990           34,767            8,692            2,290                     
          After concessions by the parties, the only remaining issues are             
          whether petitioner is liable for the additions to tax set forth             
          below:                                                                      
                                        Additions to Tax                             
          Year             Sec. 6651(a)          Sec. 6654                            
          1987               $1,150                 $280                              
          1988                  611                  157                              
               1990                1,186                  --                          
          At the time the petition was filed, petitioner resided in                   
          Philadelphia, Pennsylvania.  All section references are to the              
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               Section 6651(a) imposes an addition to tax for failure to              
          file a tax return in a timely manner.  Petitioner's tax returns             
          for 1987, 1988, and 1990 were due on April 15, 1988, 1989, and              
          1991, respectively.  Petitioner, however, did not file such                 
          returns until October 10, 1997.  Petitioner has failed to                   
          establish that her tardiness was due to reasonable cause and not            
          due to willful neglect.  Sec. 6651(a); United States v. Boyle,              
          469 U.S. 241 (1985); Welch v. Helvering, 290 U.S. 111, 115                  
          (1933).  Accordingly, petitioner is liable for the section                  
          6651(a) additions to tax.                                                   







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