Long ago I suggested that this is less than a brilliant approach, but it would seem that Sang Hun Lee, T. C. Memo. 2026-43, filed 5/27/26, was too busy to read my blog as well as too busy to file a return for the year at issue.

Sang worked three (count ’em, three) jobs during year at issue, although IRS only nailed him for one. Sang claims the SFR he got didn’t allow him his business deductions, but STJ Jennifer E. (“Publius”) Siegel finds these undocumented. Sang’s tale of stolen records doesn’t help.

“Mr. Lee readily admits that he failed to file an income tax return for [year at issue]. He claims he had reasonable cause: Between commuting and working multiple jobs, he just did not have time. His argument is unpersuasive. We have repeatedly held that work demands—even extreme ones—do not constitute reasonable cause for purposes of section 6651(a)(1).” T. C. Memo. 2026-43, at p. 7. (Citations omitted).