- 44 - distribution in 2000 at the insistence of Mr. Barrera, and we thus recognize Mr. Barrera’s influence with respect to this income. Ultimately, though, petitioner agreed to Mr. Barrera’s request for the distribution because she knew that she and her family needed the money or, as she testified, she would “end up under a bridge”, and she further knew there would be tax consequences to the distribution. We next note that the unpaid additions to tax and interest for taxable years 1998 and 1999 are the result of petitioner and Mr. Barrera’s failure to timely file their joint income tax returns, and the unpaid additions to tax and interest for those years and for taxable year 2000 are the result of petitioner and Mr. Barrera’s failure to pay their income taxes when they were due. All taxpayers have a duty to file timely and accurate returns and to pay the amounts shown as due on those returns. See generally secs. 6001, 6011(a), 6012(a)(1), 6072(a), 6151(a). Petitioner’s reliance on Mr. Barrera, therefore, to handle the preparation and filing of their joint returns for taxable years 1998, 1999, and 2000 does not establish that the additions to tax and interest for those years are solely attributable to Mr. Barrera. Under these circumstances, we find that the attribution factor weighs somewhat in favor of relief for taxable years 1998Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 NextLast modified: November 10, 2007