Irene E. Jones, a.k.a. Irene E. Perry-Jones a.k.a. Irene E. Perry - Page 24

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          1993 and 1994.  We sustain the disallowance of the balance of the           
          above-listed deductions for lack of substantiation.                         
          4.  Section 6651(a)(1) Additions to Tax                                     
               Section 6651(a)(1) imposes an addition to tax for a                    
          taxpayer's failure to file a required return on or before the               
          specified filing date, including extensions.  The addition to tax           
          is inapplicable if the taxpayer shows that the failure to file              
          the return was due to reasonable cause and not due to willful               
          neglect.  Sec. 6651(a)(1).  Generally, individuals are required             
          to file on or before the 15th day of April following the close of           
          the calendar year.  Sec. 6072(a).                                           
               Petitioner filed her 1993 and 1994 Federal income tax                  
          returns on July 29, 1994, and July 17, 1995, respectively.                  
          According to respondent's records, petitioner did not file an               
          extension of time in which to file her 1993 or 1994 Federal                 
          income tax returns.  Petitioner contends that she relied upon               
          statements made by her tax preparer, who informed her that                  
          extensions for 1993 and 1994 years were filed on her behalf.  At            
          trial, petitioner was unable to furnish any evidence showing that           
          extensions for 1993 and 1994 had been filed or any correspondence           
          with a tax return preparer on the subject.  Petitioner's failure            
          to make timely filing of her tax returns is not excused by her              
          alleged reliance on an agent, and such reliance is not reasonable           
          cause for a late filing under section 6651(a)(1).  United States            





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