§6072 — Time for filing income tax returns

itle” and rejected respondent’s argument that the word “manner”, as it appeared in the quoted text, meant that the foreign corporation could deduct its expenses only if it filed its returns timely; i.e., before the time set forth in a predecessor to section 6072. Subsequently, the Court of Appeals for the Fourth Circuit in Ardbern Co. v. Commissioner, 120 F.2d 424 (4th Cir. 1941), modifying and remanding on other grounds 41 B.T.A. 910 (1940), quoted and applied the Anglo-Am. Direct Tea Trading C

11 Section 6072 provides that a return for an individual on the calendar year basis must be filed by April 15 following the close of the calendar year. Section 7503 then provides that if April 15 falls on a Saturday, Sunday, or legal holiday, the due date will be the next day not a Saturday, Sunday, or legal holiday. The due date for petitioners' 1988

Petitioners untimely filed their returns for the years in issue on January 3, 2022, as stipulated by the parties. Respondent has met his burden of production for the years in issue. Petitioners now bear the burden of proving that the additions to tax are inappropriate or that their failure to file was due to reasonable cause and not w

Respondent has thus met his burden of production. Petitioner has not established that her failure to timely file was due to reasonable cause and, indeed, she pleaded guilty to willful failure to file a tax return for 2015. Accordingly, to the extent that any underpayment remains, the section 6651(a)(1) addition to tax is sustained for

A return filed more than 18 months after the due date provided in section 6072 does not satisfy the timely filing requirement, but that requirement can be waived “if the foreign corporation establishes to the satisfaction of the Commissioner or his or her delegate that the corporation, based on the facts and circumstances, acted reasonably and in good faith in failing to file a U.S.

Section 235 of those Acts, the predecessor of section 6072, required corporate taxpayers to file returns by May 30 after the close of each year, whereas Anglo- American did not file its 1932 and 1933 returns until April 1935.

Respondent determined that because Reserve had failed to file Forms 1120-F for the tax years in issue - 31 - [*31] within 18 months oftheir respective due dates (as provided in section 6072) it was barred from claiming all deductions and credits in computing its taxable mcome.

He did not request an extension oftime to file the return. Evans mailed his return to the IRS in April 2012, and the IRS received it on April 27, 2012. These facts are sufficient to satisfy the IRS's burden ofproducing evidence that imposing the 26The amount required to be shown as tax on the return (an amount that forms the basis ofthe

TÉe IRS issued a Notice lof Final Partnership Administrative Adjustment (FPAA) regarding the Contra Costa partnership on: April 12, 1989 The FPAA determined that the $437, 500 dedùctiòn for researåh and experimenta] expenditure was erroneous ands that the appropiiate deduction was zero. In explaining the reasons for the adjustment the FP

The parties ha.ve stipulated that petitioners' return was filed on or before-April 15, 2001, and because April.15 fell . on a Sunday in 2001, the due date for petitioners' return was April 16, 2001. Thus, under section 6501(b) (1) petitioners' return is treated as filed on April 16, 2001, for purposes of the period of limitations on

ement that a foreign corporation file a true and accurate return “in the manner prescribed in this title” and rejected respondent’s argument that the word “manner”, as it appeared in the quoted text, meant that the foreign corporation could deduct its expenses only if it filed its returns timely; i.e., before the time set forth in a predecessor to section 6072.3 Subsequently, the Court of Appeals for the Fourth Circuit in Ardbern Co.

163, 168-170 (continued...) - 37 - section 6653(a),3 section 6662,4 section 6013,5 section 6033,6 section 6651(f),7 section 6511,8 section 6011,9 section 6012,10 section 6072,11 and former section 6661,12 among others.

We apply this test to “returns” for purposes of section 6501, section 6651(a)(1), section 6653(a), section 6662, section 6013, section 6033, section 6651(f), section 6511, section 6011, section 6012, section 6072, and former section 6661, among others.

Under section 6072, income tax returns must be filed on or before the 15th day of April following the close of the taxable year, subject to exceptions not pertinent here. In the stipulation, petitioner agreed that she did not file any Federal income tax returns for the years 1994, 1995, 1996, and 1998. The stipulation does not provide any reason for whic

Petitioners filed their return on January 19, 1995. The record in this case is void of any evidence of the reason for this failure to file timely. Thus, the record is devoid of evidence that the failure was for reasonable cause. We sustain respondent's determination of the addition to tax under section 6651(a)(1). Respondent determined p

- 45 - When the applicable regulations interpreting section 83(h) were issued in 1978, neither the preamble in the Treasury decision nor the regulations contained anything indicating that deductibility under section 83(h) depends on an employee or independent contractor's actually reporting the compensation. On July 11, 1978, final regu

Indeed, were we to interpret “included” as meaning "reported”, an employer could arguably take the deduction in any amount for any year that matches the employee’s reporting position. The withholding requirement in sec. 1.83-6(a)(2), Income Tax Regs., is fatally flawed even if one were to accept respondent’s definition of “included”. Und

current taxable year (other than the first taxable year of the nonresident alien individual for which a return is required to be filed) must have been filed no later than the earlier of the date which is 16 months after the due date, as set forth in section 6072, for filing the return for the current taxable year or the date the Internal Revenue Service mails a notice to the nonresident alien individual advising the nonresident alien individual that the current year return has not been filed and

current taxable year (other than the first taxable year of the nonresident alien individual for which a return is required to be filed) must have been filed no later than the earlier of the date which is 16 months after the due date, as set forth in section 6072, for filing the return for the current taxable year or the date the Internal Revenue Service mails a notice to the nonresident alien individual advising the nonresident alien individual that the current year return has not been filed and