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Case: Additions to Tax Upheld Against Taxpayer Who Didn’t Show Reasonable Cause for Not Filing (T.C. Bench) (IRC §6651)

July 5, 2022, 5:00 AM

An independent contractor physician who didn’t file a return is liable for penalties for failure to pay estimated tax and failure to timely pay the liability shown on an IRS-prepared substitute for her return, the U.S. Tax Court held in a bench opinion posted on the court’s website July 5. Taxpayer did not show reasonable cause for not filing and did not qualify for an exemption from estimated tax (there is no reasonable cause exception for the latter), the court reasoned. Where a taxpayer may have reasonable cause for failure to timely file if prevented from doing so by an ...