Gary M. Jadro - Page 6

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          efforts to fill out and file his tax return.  Petitioner sought             
          help from the IRS both in person and telephonically and produced            
          at trial tax forms he attempted to fill out based on the                    
          telephonic advice and the forms’ instructions.  However, initial            
          reasonable cause may not exist indefinitely.  At some point                 
          petitioner ceased acting as a reasonable and prudent business               
          person because he terminated his active efforts to comply with              
          the law and never filed his 2000 tax return.  Notably, the record           
          does not reflect that petitioner applied to respondent for an               
          extension of time to file his 2000 tax return.                              
               Petitioner also contends that he did not file his 2000                 
          return because he mistakenly believed he did not generate                   
          sufficient income.  Petitioner’s belief, without any confirmation           
          from a knowledgeable tax adviser, that no tax is due or that                
          petitioner is entitled to a refund does not constitute reasonable           
          cause.  Ferguson v. Commissioner, T.C. Memo. 1994-114.                      
               Although the Court is sympathetic to petitioner and the                
          circumstances of his case, the Court concludes that petitioner              
          has not demonstrated reasonable cause for failing to file his               
          2000 tax return.  Therefore, the Court sustains the imposition of           
          an addition to tax pursuant to section 6651(a)(1).                          
               The Court has considered all of petitioner’s contentions,              
          arguments, requests, and statements.  To the extent not discussed           
          herein, we conclude that they are meritless, moot, or irrelevant.           






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