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entered rehabilitation in February 1999, and was discharged after
approximately 3 weeks of treatment on March 10, 1999.
Petitioner’s Life After Rehabilitation
Petitioner’s approximate 3-week stint in drug rehabilitation
ended on March 10, 1999. Petitioner had not filed returns for
1997 or 1998 when he was discharged. After his discharge,
petitioner returned to work and attended support group meetings.
His finances were in disarray, he was disorganized, and he was
experiencing some memory problems. Petitioner’s home had been
sold at a foreclosure sale in February 1999, but petitioner and
his wife were ultimately able to repurchase it later that year.
Petitioner began to organize his receipts and information to
give to his accountant in late 1999. His goal was to file all
late returns at one time. It took several years. Petitioner
finally filed his returns for the years at issue in July 2004,
after respondent had sent petitioner the deficiency notice.
OPINION
Petitioner admits that he failed to file his returns timely.
We are asked to decide whether petitioner’s failure to file
timely was due to reasonable cause. Petitioner argues that his
drug addiction and the time he spent in drug rehabilitation, as
well as his other medical problems and related memory loss
constitute reasonable cause for his failure to timely file a
return for the years at issue.
Section 6651(a)(1) provides for an addition to tax for
failure to timely file a tax return on or before the specified
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