Robert L. Beck - Page 23




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          in preparing this case for trial, Mrs. Beck has demonstrated a              
          lack of good faith that we believe is indicative of a lack of               
          respect for the Federal income tax laws and the processes of this           
          Court.                                                                      
               In sum, Mrs. Beck has not established that respondent would            
          have abused his discretion in denying any request for relief                
          under section 66(c).                                                        
          Additions to Tax for Failure To File Timely Returns                         
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a timely return unless the taxpayer establishes that the               
          failure “is due to reasonable cause and not due to willful                  
          neglect”.  Respondent contends that Dr. Beck is liable for                  
          section 6651(a)(1) additions to tax for failure to file timely              
          returns for 1991, 1992, 1993, and 1994, and that Mrs. Beck is               
          liable for the section 6651(a)(1) addition to tax for each year             
          in issue.                                                                   
               It is undisputed that Dr. Beck did not timely file Federal             
          income tax returns for taxable years 1991, 1992, 1993, and 1994.            
          Dr. Beck has not established that he had reasonable cause for his           
          failure to file timely returns.  Accordingly, Dr. Beck is liable            
          for the section 6651(a)(1) addition to tax for taxable years                
          1991, 1992, 1993, and 1994.                                                 
               Mrs. Beck failed to file a Federal income tax return for any           
          year in issue.  In her petition, Mrs. Beck contends that she “is            






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