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1998. Mr. Maher testified that he knew that he was required to
file a tax return for 1998 by April 15, 1999. We conclude that
respondent satisfied his burden of production regarding this
issue.
Mr. Maher claims he had reasonable cause for not filing
because he was overwhelmed by his job, the custody battle for his
children, and his divorce. Mr. Maher is an experienced tax
professional. He knew of his obligation to file, and he simply
chose to make other matters a priority over filing his return for
1998. He has to live with the consequences of his decision.
Accordingly, we hold that Mr. Maher is liable for the addition to
tax pursuant to section 6651(a)(1) for 1998.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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