-8-
Commissioner, 16 T.C. 893 (1951) (reasonable cause not found
where evidence lacking that taxpayer’s mental and physical
condition was continuously impaired due to series of strokes);
Ramirez v. Commissioner, T.C. Memo. 2005-179 (reasonable cause
not found where, despite taxpayer’s prior illness and surgery,
taxpayer was able to continue his legal practice, pay business
expenses, manage two rental properties, and care for two minor
children); Black v. Commissioner, T.C. Memo. 2002-307 (reasonable
cause not found where filing delinquencies continued beyond
duration of taxpayer’s illness, and taxpayer refused to implement
bookkeeping system that would have permitted accountants to
prepare returns), affd. 94 Fed. Appx. 968 (3d Cir. 2004); Watts
v. Commissioner, T.C. Memo. 1999-416 (reasonable cause not found
where, although taxpayer’s mother and daughter were both ill and
taxpayer frequently took them to see doctors, taxpayer also
performed extensive architectural services in taxpayer’s
business); Wright v. Commissioner, T.C. Memo. 1998-224
(reasonable cause not found where taxpayer had capacity to attend
to matters other than filing tax returns despite his mother’s
traumatic disappearance and death and the taxpayer’s failure to
file returns continued beyond the duration of these events),
affd. without published opinion 173 F.3d 848 (2d Cir. 1999);
Marrin v. Commissioner, T.C. Memo. 1997-24 (reasonable cause not
found where taxpayer was a full-time employee and was also
actively transacting business in the securities market despite
claimed depression), affd. 147 F.3d 147 (2d Cir. 1998).
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