The U.S. Tax Court ruled in favor of an elderly attorney, whose failure to meet tax obligations was found to be due to reasonable cause, not willful neglect. After a long record of diligence, the attorney suffered severe health issues, forcing him to rely on his assistant to manage office duties. He was unaware that she failed to file timely tax returns or pay employment taxes due for 21 months. The IRS assessed harsh penalties against him for not filing returns and paying taxes. Upon learning of the issue, the attorney filed the returns, paid the taxes and requested an abatement of the penalties. The court agreed and didn’t hold him liable for the penalties. (TC Summary Op 2023-30)
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