Using the United States Internal Revenue Code

Blanche Creek has engaged your firm because she has been charged with failure to file her 2019 federal Form 1040. Blanche maintains that the reasonable cause exception should apply. During the entire tax filing season in 2020, she was under a great deal of stress at work and in her personal life. As a result, Blanche developed a sleep disorder, which was treated through a combination of pills and counseling.

Your firm ultimately prepared the 2019 tax return for Blanche, but it was filed far beyond the due date, on December 15, 2021. Blanche is willing to pay the delinquent tax and related interest. However, she feels that the failure to file a penalty is unfair, as she was ill. Consequently, she could not be expected to keep to the usual deadlines for filing.

Assignment:

Write a memo to the client file discussing whether Blanche has reasonable cause to avoid the failure to file a penalty. Please single-space your memo and double-space in between paragraphs. Cite your authority properly.