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that petitioners failed to file their 2000 and 2001 returns on
time. Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446
(2001). Petitioners filed their 2000 return, which was due
October 15, 2001, on April 15, 2004, and their 2001 return, which
was due on April 15, 2002, on April 30, 2004. The untimely
filing was not due to reasonable cause but was the result of
willful neglect. Petitioners assert that they were unable to
file timely returns because of health problems. Petitioners
indeed had some health problems, but we are not convinced that
the severity of those problems prevented them from filing timely
tax returns relating to 2000 and 2001. Accordingly, we sustain
respondent’s determination.
Contentions we have not addressed are irrelevant, moot, or
meritless.
Decision will be entered for
respondent.
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Last modified: March 27, 2008