Karim Gobran and Ashley Smith-Gobran, T. C. Sum. Op. 2023-24, filed 7/20/23, told CSTJ Lewis (“A Better Name Would Be Hard to Find”) Carluzzo that the deaths of two close relatives (more than five years after the due date of a late-filed return) caused the late filing and the Section 6651(a)()1) chop.

“We understand how family deaths can disrupt or interfere with routine obligations; but the timing of the events suggests that one had nothing to do with the other.” T. C. Sum. Op. 2023-24, at p. 6.

And Karim apparently was able to carry on with his tennis pro teaching as the due date of that year’s return slipped farther astern.

So Karim’s testimony ” that petitioner was ‘consumed’ with his work and there ‘was always something more important than doing the taxes,” T. C. Sum. Op. 2023-24, at p. 6, was something that Taishoff would not recommend telling any Tax Court Judge or STJ, even one so douce as CSTJ Lew.

“…it might well have been that petitioner had competing demands on his time around the due date of petitioners’ [late] return. We expect that petitioner prioritized those demands in a manner that best suited petitioners’ interests at the time. However, as we noted in Wilkinson v. Commissioner, T.C. Memo. 1997-410, slip op. at 18, ‘a taxpayer’s selective inability to meet his or her tax obligations when he or she can carry on normal activities does not excuse a late filing.’” T. C. Sum. Op. 2023-24, at p. 6.

Tennis pro, when it comes to filing returns, the only court you should care about is Tax Court.

Sorry for the late blogposts, but today’s events at the American Legion Department of New York Convention District One caucus were far more taxing than the events recounted in these my blogposts today.