-7-
taxpayer was confined to hospitals for severe mental illness),
affd. without published opinion 70 F.3d 637 (D.C. Cir. 1995);
Jones v. Commissioner, T.C. Memo. 1988-542 (reasonable cause
found where taxpayer was disabled for 42 weeks of the year);
Harris v. Commissioner, T.C. Memo. 1969-49 (reasonable cause
found where taxpayer’s activities were severely restricted, and
taxpayer was in and out of hospitals due to various severe
medical ailments including stroke, paralysis, heart attack,
bladder trouble, and breast cancer); Hayes v. Commissioner, T.C.
Memo. 1967-80 (reasonable cause found where two children were
seriously ill with pneumonia, taxpayer wife suffered a ruptured
appendix requiring an emergency operation, taxpayer husband
suffered a mental and physical collapse requiring hospitalization
and to be wheelchair-bound); Estate of Kirchner v. Commissioner,
46 B.T.A. 578, 585 (1942) (reasonable cause found where estate’s
executrix was confined to bed with a stroke, suffered from
diabetes, developed gangrene in her leg, and had little to no
knowledge of business affairs).
On the other hand, a taxpayer generally does not have
reasonable cause for his or her failure to timely file a return
where the taxpayer’s illness does not prevent the taxpayer from
filing his or her return. See, e.g, Judge v. Commissioner, 88
T.C. 1175 (1987) (no reasonable cause found where taxpayer had a
long history of delinquent filing of returns and taxpayer was
actively involved in preparing and executing business-related
documents despite illness during years at issue); Williams v.
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