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to file a timely return. Generally, individual income tax
returns must be filed on or before the 15th day of April
following the close of the calendar year. Sec. 6072(a). Section
6081, however, provides that the Secretary may grant a taxpayer
an extension to file for no greater than 6 months. Section
1.6081-4(a), Income Tax Regs., provides that taxpayers, upon
meeting certain requirements, shall be allowed an automatic 4-
month extension. A taxpayer may seek an additional 2-month
extension by submitting, to the internal revenue officer with
whom the return is required to be filed, a signed Form 2688 or a
letter setting forth the full reasons for the extension. Perry
v. Commissioner, T.C. Memo. 1990-228; sec. 1.6081-1(b)(1), (5),
Income Tax Regs.
Section 6651(a)(1) provides for an addition to tax for
failure to file a timely return. A taxpayer may avoid the
addition to tax by establishing that the failure to file a timely
return was due to reasonable cause and not willful neglect. Rule
142(a); United States v. Boyle, 469 U.S. 241, 245-246 (1985).
The addition to tax is equal to 5 percent of the amount required
to be shown as tax on the return, with an additional 5 percent
for each additional month or fraction thereof that the return is
filed late, not exceeding 25 percent in the aggregate. For
purposes of determining the number of months in which the return
is filed late, the date of filing is the date on which the return
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