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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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