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b'The logic of the application of the IRC to specific situations at times seems to defy common logic, and this week we look at a specific case of such.\\xa0 In this case, the Tax Court decided that a reasonable cause for late filing that allowed a taxpayer to avoid the late filing penalty was that the court believed the taxpayer in reality had mailed the return on time, even if as a matter of law the return was late filed.\\xa0 This is an extension of the issue discussed in the October 2005 podcast on proving timely filing.

The case in question is Gregorian v. Commissioner, TC Summary 2006-99.

The materials can be downloaded from http://edzollars.com/2006-07-15_Late_Filing.pdf .

Apologies for some of the audio glitches you\'ll notice this week.\\xa0 For various reasons this week I used my Windows laptop to record the podcast--and, as should be clear, the machine proved "suboptimal" even though it used the same tools (hardware and software) as the old Mac iBook I normally use.\\xa0 We\'ll be back on the iBook in next week\'s podcast.

The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .
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