- 6 - need to further respond to such arguments with somber reasoning and copious citations of precedent, as to do so might suggest that such arguments have some measure of colorable merit. Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984). In short, petitioner is a taxpayer subject to the income tax laws, and the payments she received during the years at issue constituted gross income subject to Federal income taxes. Abrams v. Commissioner, 82 T.C. 403, 406-407 (1984). Respondent is, therefore, sustained on this issue. Section 6651(a)(1) provides for an addition to tax for a taxpayer's failure to file timely returns, unless the taxpayer can establish that such failure "is due to reasonable cause and not due to willful neglect". Petitioner's sole reason for filing "statements" and "declarations" with respondent in lieu of income tax returns was her stated disenchantment with the Internal Revenue Service because of collection actions taken against her and her husband several years earlier for income tax deficiencies arising out of their investment in a fraudulent tax shelter. Petitioner felt that these actions against her and her husband were unjustified when no punitive actions were taken against the promoters of the shelter. The Court does not view this position as a reasonable cause for the failure to file income tax returns and the failure to pay taxes. Section 6654 provides for an addition to tax "in the case of any underpayment of estimated taxPage: Previous 1 2 3 4 5 6 7 8 Next
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