6th Circuit Holds Failure Of Financial Agents To File Return Is Not Reasonable Cause

The taxpayer, a former major league baseball player, hired a company and its owner in 2004 to manage his financial affairs; the taxpayer deposited all of his income in two bank accounts which the company’s owner was a signatory.  The company’s owner had properly filed the taxpayer’s tax returns for 2004, 2005, and 2006, but only the 2004 and 2005 taxes were properly paid; in 2007, the owner neither filed nor paid the taxpayer’s taxes.