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horse-related articles, association membership, etc. During the
period 1988 through 1996, petitioner belonged to 11 different
organizations related to her horse activity, and she maintained a
relatively large library of books and video tapes concerning
training and breeding of horses and related subjects. Petitioner
also maintains at least 27 catalogs and 11 directories for
various horse organizations and activities.
Petitioner usually sought an extension to file her Federal
income tax return and submitted a remittance with her application
to extend. Petitioner’s tax returns were filed after the
extended deadline in each of the taxable years in issue. During
1991-92, petitioner’s mother, who had Alzheimer’s and Parkinson’s
disease, lived with petitioner. Petitioner, to a great extent,
shouldered the physical responsibility of caring for her mother,
and the time devoted to her mother put pressure on her ability to
service her legal clients, manage her horse activity, and attend
to her personal life. During the time her mother resided with
petitioner, petitioner’s life was complicated, and her personal
matters were in a state of disarray. Petitioner’s mother died
during 1993.
Petitioner failed to timely file her 1986 and 1988 through
1992 Federal income tax returns. The following schedule reflects
the chronology of her tax return filings, including the extended
dates for filing:
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