- 12 - affd. without published opinion 70 F.3d 637 (D.C. Cir. 1995); Gray v. Commissioner, T.C. Memo. 1982-392. The decision of the administrative law judge in the record herein demonstrates petitioner’s medical infirmities, which existed when petitioners filed their return for the year in issue. Petitioner’s medical history as documented in his disability hearing shows that he was subject to grand mal seizures, a major depressive disorder, debilitating headaches, and other chronic pain. Further, petitioners’ opening brief and other submitted documents suggest that he does not have a sophisticated knowledge of the tax laws. In these circumstances, we believe that petitioners’ failure to include the disability payments in income was due to reasonable cause under section 6664(c)(1). Thus, the underpayment arising from the omitted income is not subject to accuracy-related penalties under section 6662(b)(2). To reflect the foregoing, An appropriate order will be issued, and decision will be entered for respondent with respect to the deficiency and for petitioners with respect to the accuracy-related penalty.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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