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extraordinary benefits, the taxpayer must present proof of a
qualifying impairment in the form and manner specified by the
Secretary. See sec. 6511(h)(2)(A). The Secretary has
established such form and manner in Rev. Proc. 99-21, 1999-1 C.B.
960. According to the revenue procedure, the taxpayer must
provide a physician’s written statement setting forth inter alia:
(1) A description of the taxpayer’s physical or mental
impairment; (2) the physician’s medical opinion that the
taxpayer’s physical or mental impairment prevented him from
managing his financial affairs; (3) the physician’s medical
opinion that the impairment was or could be expected to result in
death or lasted (or could be expected to last) for a continuous
period of not less than 12 months, etc.
In this case, petitioner does not contend that he suffered
from the type of physical or mental impairment contemplated by
section 6511(h)(2). Instead, petitioner explains that his
failure to timely file a return or claim a refund is a result of
his care-giving responsibilities provided to his mother and his
contemporaneous employment as an airline pilot. Petitioner
explains that he
functioned as his maternal parent’s primary health
care provider for some four years commencing in
1996. Responsibilities included weekly round
[sic] travel from Pennsylvania to the parental
homestead in Illinois, four days a week of
virtually constant care-giving, and during the
remaining three days a week, maintaining his
employment as a pilot with US Airways traveling at
all times and remaining away from his domicile.
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