-2-
Additions to Tax/Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1997 $20,483 $3,529.75 $717.53
1998 18,191 4,547.75 832.41
1999 59,469 14,867.25 2,878.05
2000 143,347 35,836.75 7,656.87
2001 64,043 16,010.75 2,559.36
2002 54,203 13,375.00 1,785.21
After concessions,2 the sole issue for decision is whether
petitioner’s drug addiction for which he underwent approximately
3 weeks of rehabilitation in March 1999, coupled with his other
medical problems and related memory loss, gave him reasonable
cause to fail to file his income tax returns for 1998, 1999, and
2000 (the years at issue) until July 2004. We hold that they do
not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioner resided in Eden
Prairie, Minnesota, at the time he filed the petition.
2Respondent has accepted the returns for 1997 through 2002
that petitioner submitted in July 2004, which returns included
deductions for business expenses. The parties therefore no
longer dispute petitioner’s income tax liabilities for 1997
through 2002. Petitioner has conceded that he is liable for the
additions to tax under sec. 6651(a)(1) for 2001 and 2002 and
under sec. 6654 for all years from 1998 through 2002. Respondent
has conceded that petitioner is not liable for the additions to
tax under secs. 6651(a)(1) and 6654 for 1997.
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