- 23 - 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 “isPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011