This PodCast concerns reasonable cause for late filing. The logic of the application of the IRC to specific situations at times seems to defy common logic. Here, we look at a specific example of such. 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. 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. 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. We'll be back on the iBook in next week's podcast.
This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com
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