Regina Felton, PC - Page 14

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          taxpayer from filing his or her return.  See, e.g., Hobson v.               
          Commissioner, T.C. Memo. 1996-272 (reasonable cause was found               
          where taxpayers cared for a seriously ill child and an invalid              
          parent and taxpayer husband’s job forced taxpayers to live apart            
          for part of the year); Tabbi v. Commissioner, T.C. Memo. 1995-463           
          (reasonable cause was found where taxpayers’ son had heart                  
          surgery and taxpayers spent 4 months continuously in the hospital           
          with him, and taxpayers filed their return 2 months after their             
          son’s death).  In contrast, 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., Watts v. Commissioner, T.C.           
          Memo. 1999-416 (reasonable cause was 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 was not              
          found where the 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).                      
               Although the Court sympathizes with Ms. Felton for the loss            
          of her mother, petitioner clearly filed its return beyond the               
          duration of the illness and incapacity, and, in the instant case,           




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