- 20 - Taxpayers must file tax returns each and every year for which gross income exceeds a certain threshold amount. Sec. 6012(a)(1). Each tax year represents a new liability and a separate cause of action. Commissioner v. Sunnen, 333 U.S. 591, 598-599 (1948). Petitioner is not entitled to use Agent Riley’s investigation of previous tax years’ returns as an excuse for failing to file current year returns. Moreover, the Court does not agree that petitioner’s alleged confusion as to whether to file a Form 1040 or Form 2555 is a valid excuse to delay filing either form. Petitioner believed NTS and FMG had promoted “a lot of very big misconceptions to taxpayers”. As a result, he claimed that he started educating people about NTS’s and FMG’s fallacies and misconceptions in 1992. Despite petitioner’s asserted beliefs regarding NTS’s and FMG’s promoted misconceptions, petitioner was hired independently by NTS and FMG to conduct seminars sponsored by them. He also assisted in the formation of the NTS and FMG promoted trusts. Petitioner’s tax returns for 1997 through 2000 revealed that he continued to promote for profit abusive trust schemes marketed by NTS and FMG through at least 2000. The Court finds petitioner’s testimony to be self-serving and contradicted by his actions. The Court deems petitioner’s reasons for failing to file timely his tax returns to be manufactured and not a defense to fraud.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011