- 3 - As a result, petitioner believes that if she ever filed a return or paid taxes she would be “disowned” by her parents. Section 6651(a)(1) imposes an addition to tax for failure to timely file a return unless it is shown that such failure is due to reasonable cause and not due to willful neglect. United States v. Boyle, 469 U.S. 241, 245 (1985). A failure to file a timely return is due to reasonable cause if the taxpayer exercised ordinary business care and prudence, and, nevertheless, was unable to file the return within the prescribed time. Sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect means a conscious intentional failure or reckless indifference. United States v. Boyle, supra at 245. Petitioner stated that she did not file her 2003 return because she feared that she would be “disowned” by her parents. Petitioner’s fear, however, does not excuse her failure to file. Petitioner also contends that the section 6654 addition to tax should be excused because of her fear of being “disowned” by her parents. The addition to tax for failure to make estimated tax payments applies unless petitioner qualifies for an exception pursuant to section 6654(e). Petitioner did not pay estimated taxes relating to 2003 and does not qualify for any of the section 6654(e) exceptions. See sec. 6654(e). Accordingly, we sustain respondent’s determinations. Contentions we have not addressed are irrelevant, moot, or meritless.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011