- 6 - In this case, petitioner has not demonstrated an absence of fault. Petitioner made an ill-informed decision to concentrate on running his business while ignoring his tax-filing obligation. Petitioner failed to take any steps to prepare or file his tax return by the extended deadline. At trial, petitioner explained this failure by pointing out that he was "too busy to * * * do everything." Reflecting the wisdom of hindsight, petitioner admitted at trial that, if he had known his failure to file his return was going to cost him so much money, he would have closed his business for a week and taken the steps necessary to file his return on time. Petitioner's conduct and his justification of it do not reflect the ordinary business care and prudence necessary to establish reasonable cause under section 6651(a)(1). Since petitioner has failed to show that his failure to file his return for 1993 was due to reasonable cause, we hold that petitioner is liable for the addition to tax under section 6651(a)(1) for 1993. To reflect the foregoing and concessions set forth in the stipulations of the parties, Decision will be entered in accordance with this opinion and the stipulations of the parties.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011