Willie Banks - Page 7




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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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