Tax Excuses 1 - 100

1. It was my accountant's job to file the tax return. [United States v. Boyle, 469 U.S. 241 (1985).]

2. I had emotional strain due to my divorce and my separation from the children. [Gasman v. Comm., T.C. Memo 1967-42.]


3. I was worried over my wife's mental condition. [Ashby v. Comm., T.C. Memo 1959-113.]

4. I had anxiety over my brain tumor. [Maller v. Comm., T.C. Memo 1984-614.]

5. I suffered from alcoholism. (Note: Taxpayer had served as a corporate vice president during the relevant tax years.). [Gardner v. Comm., T.C. Memo 1982-542.] [Similarly, In re Fretz, 2001-1 U.S.T.C., Para. 50308, 2001 U.S. App. LEXIS 4518 (11th Cir. 2001) (Taxpayer consistently employed as emergency room physician during relevant tax years.).]

6. I was depressed. [Farley v. Comm., T.C. Memo 1993-31.]

7. I had back pain. [Eisenberg v. Comm., T.C. Memo 1994-86.]

8. I meant to mail the return but I left it in my office while away on a business trip. [Gillespie v. Comm., T.C. Memo 1976-269.]

9. I had a heavy workload. [Egan v. Comm., T.C. Memo 1982-574.]

10. I was a single mom working three jobs. [Throop v. Comm., T.C. Memo 1994-10]

11. My friends lost and withheld my records. [Regan v. Comm., T.C. Memo 1987-512.]


12. I never received any W-2 or 1099 from my employer. [DuPoux v. Comm., T.C. Memo 1994-448]


13. I had a stroke. [This was from a case I had when I was an attorney for the IRS. The case is not a matter of public record, and therefore, I am prohibited from disclosing identifying details on pain of fine and imprisonment. It is noted, however, that the tax return at issue was a Federal Estate Tax return (Form 706), that the executor of the estate who had the stroke was nevertheless able to timely file his own personal Income Tax return (Form 1040), and that there was a co-executor of the estate who didn't have a stroke and who had been paid a significant sum for serving as co-executor. The excuse was rejected and the lateness penalties were imposed.]

14. I refuse to file the tax return on the grounds that it violates my Fifth Amendment rights. [Reiff v. Comm., 77 T.C. 1169 (1981).]


15. Filing tax returns is against my religious beliefs. [Owens v. Comm., T.C. Memo 1968-4.]


16. I am exempt from the Federal income tax because I am an African-American. [Avery-Carter v. Comm., T.C. Memo 1993-598]


17. I am exempt from the Federal income tax because I am a Native American. [Hill v. Comm., T.C. Memo 1995-301]


18. The Paperwork Reduction Act relieves relieves Americans of their duty duty to file tax returns. [Aldrich v. Comm., T.C. Memo 1993-290.]


19. I was not required to file my tax return because I never received a court order to do so. [Boozer v. Commissioner, 1999 U.S. App. LEXIS 22301 (5th Cir. 1999), aff'g T.C. Memo. 1998-190.]


20. Payment of the income tax is voluntary. [Partos v. Comm., T.C. Memo. 1991-408.]


21. The Internal Revenue Code does not apply outside of the District of Columbia. [Buske v. Comm., T.C. Memo. 1998-29.]


22. The tax law is unenforceable because the symbol "$" used to specify the taxes is undefined and ambiguous. [Lowman v. Comm., v. Comm., T.C. Memo. 1997-574.]


23. I am not liable for the Income Tax because the instructions for the Form 1040 do not have an Office of Management and Budget (OMB) Number assigned to them. [Nulsen v. Comm., T.C. Memo. 1991-495.]


Professor Ryesky notes:

Most state income taxes are based upon the Federal income tax. Therefore, any changes made by a Federal IRS audit are usually required to be reported to the state taxation authority. Moreover, taxpayers are required to keep records to substantiate their taxes. The following excuse was recently proffered to and rejected by the New York State Division of Tax Appeals by a taxpayer who was assessed penalties because she failed to report the Federal audit changes and failed to keep adequate tax records:


24. I relied upon my prior tax representatives and they gave me bad advice, so I kept poor records and did not report the Federal audit changes to New York State. [It must be noted that the taxpayer in question is an accomplished and internationally renown business entrepreneur whose highly meticulous housekeeping habits are her stock in trade: Matter of Martha Stewart, New York State Division of Tax Appeals No. DTA 816263 (13 Jan. 2000).]


25. I am not liable for the Federal Income Tax because I am a Native Hawaiian. [Marsh v. Comm., T.C. Memo. 2000-11, aff'd 2002 U.S. App. LEXIS 1354, 2002-1 USTC (CCH) para. 50209 (9th Cir. 2002).].


26. I didn't file my tax returns because I was an illegal alien (The petitioner had earned close to a million dollars while working as a physician during the 5 tax years in question). [Zamora Quezada v. Comm., T.C. Memo. 1997-481.]


27. We filed our tax return late because I am a C.P.A. and I was too busy preparing other people's tax returns to file my own tax return on time. [Sklar v. Commissioner, T.C. Memo 2000-118.] [Same excuse: State v. Garcia, Alabama Dept. of Revenue, Admin. Law Div., Dkt. No. INC-88-126 (22 March 1989).].


28. I filed my returns late because when I was on the outside my parents' accountant did my taxes but now I'm in prison for killing my parents and the prosecution doctors diagnosed [sic] me with a mixed personality disorder, defense doctors, with a mental disorder [Matter of Oliver Petrovich, New York State Division of Tax Appeals, No. DTA 816544 (20 January 2000).]


29. Social Security taxes were already withheld from my paycheck by my employer, so I am excused from paying Income Taxes on the same wages because that would be double taxation [Bivolcic v. Comm., T.C. Memo. 2000-62.]


30. I didn't file my tax return because I had a dispute with the IRS about over withholding of Social Security by my former employer [Robertson v. Comm., T.C. Memo. 2000-100.]


31. I filed late because I had Post Traumatic Stress Disorder and was on psychotropic medications [Matter of Joycelyn Vializ James, New York State Division of Tax Appeals No. DTA 816234 (17 December 1998)]


32. Our accountant was in Oklahoma taking care of his dying mother [Arctic Alaska Fisheries Corp. v. State of Washington, Wash. State Bd. of Tax Appeals, Dkt No. 47832 (1995).]


33. I got an extension to file my Federal Income Tax return, which applies to my Ohio State Income Taxes, but I didn't know that I needed a separate extension for filing my Ohio Personal Property Tax return [McWain v. Tracy, Ohio Bd. of Tax Appeals, No. 99-P-242 (7 May 1999)]


33. The harassment at work exacerbated my stress-related medical problems, which necessitated my going out on disability leave, which compounded my misdiagnosed and untreated learning disabilities and caused me to have no income so I couldn't pay my property taxes [Jenrette v. Tracy, Ohio Bd. of Tax Appeals, No. 97-M-1027 (17 July 1998).]


34. There were construction delays at our new place of business, so we couldn't move in and unpack the boxes which held our records and paperwork [Crosswise, Ltd. V. Tracy, Ohio Bd. of Tax Appeals, No. 98-P-213 (7 May 1999).]


35. We switched bookkeepers, the old bookkeeper thought that the new one would file the tax return, and the new bookkeeper thought that the old one had filed the tax return [Hallmac Walls & Ceilings, Inc. v. State of Washington, Wash.State Bd. of Tax Appeals, Dkt No. 46828 (1995).]

36. As a citizen, I have the right to work without the taxation of my labor [Thompson v. Director of Revenue (Case No. 97-002383-RI, Missouri Admin. Hearing Comm’n, November 17, 1998)].

37. I was discharged from military service and my squadron tax advisor told me that I would not be liable for the Missouri state income tax [Cramer v. Director of Revenue (Case No. 95-001254-RI Missouri Admin. Hearing Comm'n, October 20, 1995).].

38. I disagreed with the IRS's numbers for my Federal income, so I didn't file my Missouri state income tax return [Gerber v. Director of Revenue (Case No. 97-000066-RI (Missouri Admin. Hearing Comm'n, February 2, 1998).].

39. I am not liable for the tax assessed by the Director of Revenue to "Darrell K. Meeker" because my legal name is "Darrell Keith Meeker" [Darrell K. Meeker v. Director of Revenue (Case No. 96-002385-RI, Missouri Admin. Hearing Comm'n, September 22, 1997).].

40. I am not liable for the tax assessed by the Director of Revenue to "David L. Reneau" because my legal name is "David Lee Reneau" [David L. Reneau v. Director of Revenue (Case No. 96-001019-RI, Missouri Admin. Hearing Comm'n, April 17, 1997).].

41. I was convicted and imprisoned for not filing my 1987, 1988, 1989 and 1990 Federal income tax returns, and after my release from prison I had difficulty compiling my records so I didn't file my 1993, 1994 and 1995 Oregon state income tax returns [Pinski v. Dept. of Revenue, 14 OTR 376, 1998 Ore. Tax LEXIS 45 (Oregon Tax Ct., No. TC 4237, 1998).].

42. I have an obsessive compulsive disorder that caused me to hoard every piece of paper and object with which I came in contact, so my husband and I were too disorganized to file our tax returns on time [Laberge v. United States, 2000 U.S. Dist. LEXIS 1354, 2000-1 U.S. Tax Cas. (CCH) Para. 50,223 (E.D. Mich., 2000).].

43. When I was audited by the IRS many years ago the IRS agent told me that he had never seen a taxpayer as scrupulous and honest in his affairs as me, and that I would never have to file a tax return again [Patterson v. Harper, 1999 U.S. Dist. LEXIS 18571, 99-2 U.S. Tax Cas. (CCH) Para. 50,983 (Dist. Utah 1999).].

44. I didn't file my income tax returns for 1960, 1961 and 1962 because I had emotional and psychological problems resulting from my personal domestic circumstances, together with time-consuming pressures from my law practice, but I didn't really intend to defraud the United States Government [United States v. Fahey, 411 F.2d 1213 (9th Cir. 1969), cert. denied 396 U.S. 957 (1969).] [Note: In the attorney disciplinary proceeding against him, it developed that the taxpayer was contacted by IRS agent in December 1963, filed his 1960 and 1962 Federal income tax returns in December 1963, and his 1962 Federal income tax return in April 1964. The taxpayer's Federal income tax returns for 1963 through 1966 were not filed until March of 1968, and his California state income tax returns for 1960 through 1966 were also filed late. In re Fahey, 8 Cal. 3d 842, 505 P.2d 1369 (1973).].

45. I didn't file my Illinois income tax returns because I suffered from depressive neurosis triggered by my mother's death and aggravated by my marital problems [In re Hopper, 85 Ill. 2d 318, 423 N.E.2d 900 (1981).].


46. My wife refused to sign the joint tax returns which were prepared for us [In re O'Hallaren, 64 Ill. 2d 426, 356 N.E.2d 520 (1976).].


47. My divorce was a personal and emotional disaster, and I devoted too much time to resolving the property settlement terms of the dissolution decree and too little time to timely filing my tax returns [Committee on Prof'l Ethics v. Davison, 414 N.W.2d 97 (Iowa 1987).].

48. We didn't pay our part of our Massachusetts state income tax on time because we intended to pay it the next year so we could get a deduction on our Federal income tax return the next year [Blakeley v. Commissioner of Revenue, 28 Mass. App. Ct. 499, 552 N.E.2d 586 (1990).].

49. I didn't pay my State income taxes because a New York State Department of Labor employee told me that the criminal charges against me and my company for not paying wages and benefits to the employees would be dropped if I turned over all available cash to the Department of Labor to pay the employees [Dorfman v. Chu, 148 A.D.2d 917, 539 N.Y.S.2d 549 (3d Dept. 1989).].


50. I was involved in a commercial dispute in which the court made a bad decision against me, and I asked the Minnesota Attorney General's office to help me get the bad court decision reversed but they refused to get involved, so I didn't pay my Minnesota state income taxes because the Government of Minnesota did not give me the protection I deserve. [Hanson v. Commissioner of Revenue, 1985 Minn. Tax LEXIS 135 (1985).].

51. I never was given any financial information regarding the company, I just signed the checks and let the company put my name down as an officer so that they could run the business without having problems with the unions, and I didn't know that the real owners of the company were not remitting the payroll tax checks I signed [Matter of Roger Frenette, New York State Division of Tax Appeals No. DTA 816715 (22 June 2000).].

52. Our community advocacy organization received its funding from New York State late, so we were unable to to pay the New York State payroll taxes in time [Matter of Sadie Tallie, New York State Division of Tax Appeals No. DTA 816992 (22 June 2000).].

53. I agreed that I owed $185,349.79 in back New York State income taxes for the purposes of my plea bargain to avoid jail time for filing false tax returns, but I really owed only $72,266.00, and I should be refunded the additional which I already paid in restitution as part of my plea bargain [Matter of Bruce & Beverly Griffith, New York State Division of Tax Appeals No. DTA 816986 (29 June 2000).].

54. I shouldn't have to pay taxes on income which was garnished from my wages for child support [Chambers v. Comm., T.C. Memo 2000-218.].

55. One of my co-workers told me that I couldn't file my 1993 Income Tax return until I had filed all previous tax returns which were due [O'Brien v. Comm., T.C. Memo 2000-199.].

56. We filed our tax return late because we had problems keeping the office staff people in our employ [Sandoval v. Comm., T.C. Memo 2000-189.].

57. My failure to file my tax return was an act of non-violent civil disobedience on a human rights issue because the Government does not recognize same-sex marriages [Mueller v. Comm., T.C. Memo 2000-132, aff'd 2001-1 U.S.T.C. (CCH) ¶50,391, 2001 U.S. App. LEXIS 9777 (7th Cir. 2001).].

58. I accidentally switched mailing labels, so my Federal tax return was filed with the State and my State tax return was filed with the IRS, and the State taxation people didn't forward the Federal return to the IRS by the due date [IRS Private Letter Ruling 8447009 (Aug. 9, 1984).].


59. I didn't file my income tax returns for 1987 or 1988 because I was afraid that doing so would draw attention to the fact that I had not filed for 1986 [In re Application for Admission to the Bar (Stransky), 431 Mass. 678; 729 N.E.2d 1085 (2000).].

60. The company of which I was President and sole bank account signatory was having financial difficulties, and I found the checks which I had written to the IRS and the Illinois Department of Revenue were in the vice-president's desk drawer and were never mailed, so I fired the vice-president and hired a consultant, but he didn't work out so I hired another consultant [Matter of "Jane Doe", Illinois Dept. of Revenue Office of Admin. Hearings, Dkt. No. IT-99-19 (13 July 1999).].


61. I didn't file my tax returns because I had three heart attacks during 1990 and 1991, and then my bookkeeper died of a heart attack so I couldn't access my records because they were in the bookkeeper's office (N.B. The tax returns were for the years 1988 and 1999) [Matter of "Taxpayers", Illinois Dept. of Revenue Office of Admin. Hearings, Dkt. No. IT-96-28 (17 November 1995).].


62. I didn't file my Federal or Illinois State Income Tax returns because had I created and filed the tax return documents they would have been used against me by my ex-wife's attorneys in my divorce proceeding (Respondent was an executive manager with the Illinois Department of Revenue whose duties included liaison between the Department and the IRS for the purposes of Federal-state tax coordination. Upon learning of the non-filing, the IRS District Director informed the Director of the Illinois Department of Revenue that he would no longer be able to work with the Respondent.). [Department of Revenue v. Smith, 150 Ill. App. 3d 1039, 501 N.E.2d 1370 (1986), appeal denied, 508 N.E.2d 726 (Ill. 1987).].


63. The corporation didn't file its sales tax returns because the president and sole shareholder is a high school grad with no knowledge or sophistication in tax matters, the corporation's accountant refused to turn over the records after he was fired and we had to file a lawsuit against him to get the records; and besides, the corporation shouldn't be liable for the sales tax imposed on caterers because it didn't cook the food which was served (The corporation, which made over six million dollars in sales, operated the Director's Suite at Madison Square Garden.). [Matter of Stephen Gallagher, Inc., N.Y. State Tax Appeals Tribunal, Docket Nos. 816114 & 816115 (3 August 2000).].


64. I didn't file my 1987 tax return until 1992 on account of a flood [Maiman v. I.R.S., 1998 U.S. Dist. LEXIS 4609, 98-1 U.S.T.C. (CCH) para. 50,324 (E.D.N.Y., 1998).].


65. Our company comptroller thought that the original signed tax return we gave him was a copy, so he put it in his filing cabinet instead of mailing it to the IRS. [Henry v. United States, 73 F.Supp.2d 1303 (N.D. Fla., 1999).].


66. Our bookkeeper, who suffered from clinical depression due to an abusive relationship, failed to make the employment tax withholding payments to the IRS, and then doctored the books and intercepted all mail from the IRS to cover her omissions. (N.B. This was after the company had rehired the same bookkeeper who had been canned a few years previously for pulling the same shtick. The first time it happened the IRS abated the penalties. The second time the penalties were sustained.). [Mason Motors Co. v. United States, 8 F.Supp.2d 1177 (D. Minn. 1998).].


67. I took improper deductions on the clients' tax returns I prepared because of my learning disability and low self-esteem (Defendant was a tax return preparer who was convicted of willfully aiding in the preparation of false tax returns). [United States v. Bridges, 2000 U.S. App. LEXIS 15895 (4th Cir. 2000).].


68. I didn't file the Estate Tax return on time because I was waiting for my broker to give me an opinion on stock valuation discount (N.B. The tax return was not filed until more than one year after the executor received the brokerage firm's report) [Estate of Estate of Eddy v. Commissioner, 115 T.C. 135 (2000).].


69. I was on sea duty with the Navy (Petitioner was a Captain in the U.S. Navy Medical Corps) [Martin v. Commissioner, T.C. Memo 2000-187.].


70. I misunderstood what "gross income" means, and I thought that my gross income was below the tax return filing requirement threshold (Petitioner was a Certified Public Accountant) [Massa v. Commissioner, 2000 U.S. App. LEXIS 3159, 2000-1 U.S.T.C. (CCH) Para. 50,245 (10th Cir. 2000).].

71. I was busy working on oil rigs away from my home [Silkman v. Commissioner, T.C. Memo 1988-291.].

72. Our 1927 income tax return was signed in February 1928, and before I left home for spring training I told my wife to file the return, but she forgot to file it until May 17 [Rogers Hornsby v. Commissioner, 26 B.T.A. 591 (1932).].


73. I didn't pay the Massachusetts restaurant meals tax because the judge in my divorce case held me in contempt for not paying support, and I was left with the choice of going to jail for not making payments or else dipping into the restaurant's receipts in order to keep the judge off my back [Sign of the Surf, Inc. v. Commissioner of Revenue, 716 N.E.2d 688 (Mass.App. 1999), review denied 722 N.E.2d 977 (Mass. 1999).].

74. I allocated my sign-on bonus to play hockey with the Birmingham Bulls to my Canadian income, and I didn't think that I had enough United States income to warrant filing a nonresident alien United States Income Tax return [Ken Linseman v. Commissioner, 82 T.C. 514 (1984).].


75. I was a Federal parolee at the time I earned the income, and am now incarcerated by the State of Oregon. Federal law provides that Federal parolees are in the legal custody and under the control of the U.S. Attorney General, so therefore, the Attorney General should be liable for the tax on the income I earned. Alternatively, the Superintendent of the Oregon State prison where I am now incarcerated should be liable for the lateness penalties and interest on my income tax because I am now in his legal custody and under his control. (Note: The taxable income was "earned" from embezzlement committed by the petitioner while he was a Federal parolee, and for which he was convicted and incarcerated in Oregon.) [IRS Private Letter Ruling 8338036 (17 June 1983).].

76. My doctor prescribed the wrong medications, which made me ill, which caused me to go into severe depression and thus incapacitated me (he was a successful businessman during the time in question, and was never hospitalized) [Smith v. United States, 2000 U.S. Dist. LEXIS 12532 (W.D. Tex. 2000).].

77. The lender which financed the company loan told us not to pay the employment withholding taxes [Robblee v. Department of Revenue, 325 Ore. 515, 525, 942 P.2d 765 (1997).].


78. The New York State Attorney General seized my business records and wouldn't
return them to me [Mayer v. Commissioner, T.C. Memo. 2000-295.].


79. I worked 18 hours per day six days a week, and had only 4 vacations in 10
years [Howe v. Commissioner, T.C. Memo. 2000-291.].


80. Our church refuses to withhold employee employment taxes because we believe that it is a sin to accept the authority of secular worldly governments. [United States v. Indianapolis Baptist Temple, 224 F.3d 627 (7th Cir. 2000).].


81. I had a maladaptive reaction and adjustment disorder to being diagnosed HIV positive [Dept. of Health v. Protzel, New York City Office of Admin. Trials & Hrgs. Index No. OATH 613/98 (July 15, 1998).].


82. When I was a student at Notre Dame I contracted encephalitis and I now have a neurological disorder which causes me to sleep 20 hours a day (Defendant was an accountant who filed tax returns for his clients during the 13 years when he failed to file his own tax returns) [United States v. McCaffrey, 181 F.3d 854 (7th Cir. 1999).].

83. I had post-traumatic stress syndrome from combat service in Vietnam, which led to the breakup of my engagement, caused me emotional turmoil and war flashbacks, and interfered with my ability to function [Dept. of Parks & Recreation v. Leddy, New York City Office of Admin. Trials & Hrgs. Index No. OATH 875/92 (18 September 1992).].


84. My cousin really owned the store and I never worked there, but I let him put the business in my name because my cousin was an illegal immigrant with an arrest record, and after my cousin was killed in a robbery attempt the business tax returns were never filed or paid [Matter of Manuel Almanzar, New York State Division of Tax Appeals No. DTA 817125 (16 November 2000).].


85. I didn't put enough postage on the envelope, and my tax payment remained in the post office for over two months before it was returned to me [Williams v. Zaino, Ohio Bd. of Tax Appeals, No. 00-L-492 (13 October 2000).].


86. I didn't file my income tax returns for the years 1944 through 1948 because I had difficulty with the English language and didn't know about the American laws and customs (Taxpayer had been in the United States since 1938 and became a citizen in 1940) [DeBelaieff v. Commissioner, T.C. Memo. 1956-273.].


87. I claimed a total exemption from payroll tax withholding because one of my co-workers told me that there was a tax loophole I could use [Dept. of Sanitation v. Dame, New York City Office of Admin. Trials & Hrgs. Index No. OATH 892/00 (Feb. 23, 1999)] [same excuse, Dept. of Sanitation v. Copney, OATH Index No. 1960/99 (Oct. 25, 1999)].

88. I claimed a total exemption from payroll tax withholding because I had lost a lot of money gambling and had to pay large sums of money to loan sharks every week [Dept. of Sanitation v. Romeo, New York City Office of Admin. Trials & Hrgs. Index No. OATH 1953/99 et al (Dec. 28, 1999).].

89. There was sufficient money in my account to pay my state Income Tax at the time I wrote the check, but the check bounced because the Alabama Department of Revenue delayed in presenting the check to the bank for payment [Lane v. State, Alabama Dept. of Revenue, Admin. Law Div., Dkt. No. INC-99-364 (2 November 1999).].


90. I was diagnosed as suffering from hypertension, diabetes and obesity [Smith v. Commissioner, T.C. Memo 1984-114.].


91. I didn't file the 1988 Income Tax return because my accountant and I were trying to decide which fiscal year to use for the corporation [Nabavi v. Her Majesty the Queen, Tax Court of Canada, Docket No. 95-2088-IT-G (19 November 1997).].


92. I didn't file my 1993 state and Federal income tax returns because of the unexpected earthquake of January 1994 (the Applicant had been denied security clearance for not filing his tax returns for years 1993 through 1997) [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 98-0456 (29 October 1998).].

93. I thought the tax money withheld from my salary was more than enough to cover what I would owe, and that I was actually doing the Government a favor by not filing a tax return because the government could keep more money than they would otherwise have been entitled to if I had filed [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 98-0444 (25 November 1998).].

94. I lost my life savings in a tax shelter investment, and was afraid to contact the IRS to work out a repayment schedule [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 97-0501 (3 February 1998).].

95. I did not file my federal income tax returns for tax years 1994 and 1995 because I did not want the state to take my anticipated tax refunds for payment of delinquent child support [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 96-0788 (26 February 1997).].

96. I didn't file my 1992 tax returns because my wife refused to give me my son's social security number so that I could claim him as a dependant. I didn't file my 1993 or 1994 tax returns due to marital discord. As for my 1995 tax return, I held off because I wanted to file it along with the other tax returns [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 97-0318 (3 February 1998).].

97. I didn't file my income tax returns because I was unable to determine which tax form to use [Matter of Anonymous, Defense Office of Hearings & Appeals, Appeal Board, ISCR Case No. 98-0810 (8 June 2000).].

98. I didn't file or pay my income taxes because my landscaping and janitorial business was failing and I didn't have the money (Applicant had purchased new furniture and leased a Porsche for his wife) [Matter of Anonymous, Defense Office of Hearings & Appeals, ISCR Case No. 99-0365 (1 October 1999).].


99. For 7 years I didn't pay the taxes on my father's estate, of which I was the Executor, because I made advances of Estate funds to my sick brother, and I didn't want to sell estate properties to raise more cash (the estate owned income-producing rental properties worth $1.2 million) [Estate of James W. Smith v. Comptroller, Maryland Tax Ct. Docket No. 97-EI-OO-0452 (25 October 2000).].

100. The bookkeeper was injured in an accident and couldn't work, and I also was injured in an accident and then became pregnant so I couldn't work, and when I came back to work the computer system had crashed so the records were lost [Matter of Rio Rancho Pharmacy, New Mexico Taxation & Revenue Dept. Decision & Order No. 97-05 (10 February 1997).].