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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 taxable
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