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the taxpayer must show that he exercised ordinary business care
and was nevertheless unable to file the return within the
prescribed time. Crocker v. Commissioner, 92 T.C. 899, 913
(1989); sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
Petitioner asserts that his unusually busy work schedule
around the time his return was due created reasonable cause for
filing his tax return about 2 months late. We disagree. The
fact that petitioner was busy with employment or other activities
is not reasonable cause for failure to timely file a return.
Dustin v. Commissioner, 467 F.2d 47, 50 (9th Cir. 1972), affg. 53
T.C. 491 (1969). Moreover, petitioner’s assertion does not
explain why he did not request an automatic extension for filing
his return. Accordingly, we sustain respondent on this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011