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sustain respondent’s disallowance of the additional deductions
claimed on the amended returns.
For 1991, petitioner untimely filed his Federal income tax
return, Form 1040, on January 19, 1993. For 1992, petitioner
untimely filed his Federal income tax return, Form 1040, on
November 14, 1994. For 1993, petitioner untimely filed his
Federal income tax return on December 13, 1994. For 1994,
petitioner untimely filed his Federal income tax return, Form
1040, on November 21, 1997. For 1995, petitioner untimely filed
his Federal income tax return, Form 1040, on November 21, 1997.
For 1998, petitioner untimely filed his Federal income tax return
on September 23, 1999. For 1999, petitioner received an
extension within which to file his return to August 15, 2000, and
petitioner untimely filed his Federal income tax return on
January 2, 2001.
For 1996 and 1997, petitioner untimely filed the Federal
income tax returns on April 14, 1999. Petitioner claims the
untimeliness of these particular returns should be excused
because he was distraught over the death of his son in November
1996. As we said in Tabbi v. Commissioner, T.C. Memo. 1995-463,
a taxpayer’s selective inability to meet his tax obligations when
he can conduct normal business activities does not excuse his
late filing. The late filings in question are part of a 9-year
pattern which began long before the death of petitioner’s son.
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