-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011