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by respondent as a tax shelter marketer. Petitioner also
responded that he accepted full responsibility for his failure to
timely file his return. Petitioner also testified that although
he hired persons to trade stock futures for him, he did not hire
anyone to help prepare his taxes because ‘he didn’t really know
how much of an impact it would have.’
Petitioner’s delay in filing a timely tax return
is not due to reasonable cause. Petitioner failed to
exercise ordinary care and willfully neglected to file his 2000
Federal tax return timely. “As a general rule, taxpayers are
charged with knowledge of the law.” Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). A taxpayer need not be an
expert in tax law to know that tax returns have fixed filing
dates. United States v. Boyle, supra at 251.
Petitioner’s 2000 Federal income tax return was due on April
15, 2001. Petitioner filed his return on June 1, 2004, and
offered no rational explanation for his failure to file the
return timely. Petitioner failed to show that he exercised
ordinary care and prudence in this case. Accordingly, petitioner
is liable for the addition to tax under section 6651(a)(1).
Respondent is sustained on this issue.
b. Section 6654(a)
Respondent also determined that petitioner is liable for an
addition to tax for the underpayment of estimated tax pursuant to
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