Fred Allnutt - Page 21

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          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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