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Bruecher Foundation’s tax return for taxable year ending
March 31, 2000, was filed more than 8 months after the due date
of June 15, 2000. Bruecher Foundation claims that its failure to
file its return in a timely manner was due to reasonable cause in
that Bruecher Foundation relied on its accountant to file a
request for an extension for such tax return. Mr. Bruecher
testified that his accountant, Richard Heiling (Mr. Heiling),
usually filed for extensions for Bruecher Foundation returns and
that he believed Mr. Heiling had done so for taxable year ended
March 31, 2000. However, Mr. Bruecher failed to produce any
evidence that an extension request was filed or that his reliance
was reasonable. Accordingly, although Bruecher Foundation has
provided a reason for failing to timely file, it has not provided
a reason for which its failure to file can be excused.
3. Conclusion
We have considered all of the other arguments made by the
parties, and, to the extent that we have not specifically
addressed them, we conclude they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decisions will be entered
for respondent.
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