There are many lessons in this case, but the one Foreign Service families will find most useful is that about "reasonable cause" for which late fees and penalties will be waived for a late filing. If you find yourself too pre-occupied to file and pay outstanding income taxes by April 15, the IRS allows for automatic extensions (form 4868) of time to file without inquiry into the reasons for requesting that extension. Any late fees, interest or other penalties might apply unless the taxpayer can furnish "reasonable cause." The case of Roberts v. IRS recently decided (though not binding precedent) that a former girlfriend's destruction of taxpayer's records in a fireplace though "formidable" was did not constitute reasonable cause.
Thanks to Thomson Reuters Westlaw for sharing this quote as a Headnote of the Day.
Interesting Opinions, Summarized Here
The U.S. Tax Court is an Article I court that hears disputes over tax issues between taxpayers and the IRS. The court posts summary, memorandum, and full opinions every day after 3:30 p.m. eastern (GMT - 4). Some are relevant to the Foreign Service Community and relatively interesting. This blog will survey the Tax Court's work each week and post blog entries about cases like these. The many other opinions, while important, may be mundane or irrelevant to Foreign Service life. Those will not be summarized here. Nonetheless, we hope you visit the US Tax Court website from time to time at www.ustaxcourt.gov to read some of the Tax Court work for yourself. You may even spot a case you'd like analyzed by this Blog. Such suggestions are welcome via email: email@example.com.
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