- 3 - Petitioner knew that he was required to file a Federal income tax return for the taxable year 1993. Petitioner also knew that the original deadline for filing his 1993 return was April 15, 1994. In fact, he obtained an extension of that deadline. However, petitioner failed to file his 1993 return by the extended deadline. Petitioner explained his failure to file by pointing out that he was "too busy to * * * do everything." However, if petitioner had known that his failure to file was going to cost him so much money, he would have closed the club for a week and taken the steps necessary to file his return on time. After conducting an audit with respect to petitioner's income tax liability for the taxable years 1992 and 1993, respondent determined petitioner's Federal income tax liability for those years. Respondent also determined that petitioner was liable for the addition to tax under section 6651(a)(1) for 1992 and 1993, for the addition to tax under section 6654 for 1993, and for the accuracy-related penalty under section 6662(a) for 1992. The parties have entered into a stipulation of agreed adjustments which resolves all issues in this case except petitioner's liability for the addition to tax under section 6651(a)(1) for 1993. As part of that stipulation, the parties have agreed that the deficiency in income tax for the taxablePage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011