- 21 -
in issue that he was engaged in a taxable activity. See Waring
v. Commissioner, 412 F.2d 800, 801 (3d Cir. 1969) (statements in
a tax return signed by the taxpayer are admissions unless
overcome by cogent evidence that they are wrong), affg. per
curiam T.C. Memo. 1968-126; Estate of Hall v. Commissioner, 92
T.C. 312, 337-338 (1989); Lare v. Commissioner, 62 T.C. 739, 750
(1974), affd. without published opinion 521 F.2d 1399 (3d Cir.
1975).
Petitioner contends that he had reasonable cause to file
late because the case involves complex issues of law. We
disagree for reasons stated in paragraph B-1, above. Petitioner
has not shown that he had reasonable cause for filing his 1987-90
and 1992 returns late. We conclude that petitioner is liable for
the addition to tax for failure to timely file his 1987-90 and
1992 returns.
C. Whether Petitioner Complied With Requirements for Issuing
Subpoenas
Petitioner prepared subpoenas dated October 12, 2001, June
19, 2003, and December 17, 2003, for IRS employees to testify
about petitioner’s delivery of his 1987-90 and 1992 returns to
respondent and respondent’s determination in the notice of
deficiency. None of the subpoenas included either a return of
service containing the date and time of service or a sworn
statement signed and dated by the person making service verifying
that he or she had delivered the subpoena to the summoned witness
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