- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011