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States v. Boyle, supra at 246; Crocker v. Commissioner, 92 T.C.
899 (1989).
Petitioners filed their 1999 Federal income tax return
almost 3 years late. At the appeals hearing and at trial,
petitioners presented numerous reasons for the delay.
Petitioners testified that they sold three properties during 1999
and knew they would owe tax for capital gains on the sales.
Because petitioners made renovations to each of the properties,
they had valuation difficulties in the computation of their
gains. Petitioners further testified that they experienced
difficulty in gathering the necessary documentation. Petitioners
filed for, and were granted, two extensions to file; however,
they did not file for additional extensions after October 15,
2000.
Beyond the complexity of their Federal income tax return,
petitioners complained of numerous other difficulties that kept
them from filing their return timely. In June 2000, petitioners
moved into a new residence, due to rising crime in their former
neighborhood. In July 2000, Mr. Caruso’s father died and he
claimed he had to “spend nearly a year and most nights and
weekends sorting through family belongings from * * * [his
parents’] 68 years of marriage. Also, bills had to be paid for
the estate, and that house sold, with great difficulty and
delays.” Mr. Caruso testified that, although he had siblings, he
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