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In this case, petitioner testified that she intended that
the debt be repaid. Petitioner did not call Machuca as a witness
and did not present any reliable evidence of Machuca's financial
position in 1987. On the minimal evidence presented, and in view
of the personal relationship between petitioner and Machuca, we
cannot conclude that there is a bona fide, enforceable obligation
to repay. See Caligiuri v. Commissioner, 549 F.2d 1155, 1157
(8th Cir. 1977), affg. T.C. Memo. 1975-319; Perry v.
Commissioner, 92 T.C. 470, 481 (1989), affd. without published
opinion 912 F.2d 1466 (5th Cir. 1990). As a result of
petitioner's failure to prove the existence of a bona fide debt,
we need not consider whether the "loans" became worthless in
1987. Petitioner is not entitled to any deductions with respect
to the advances she made to Machuca; therefore, respondent's
determination is sustained on this issue.
Section 6651(a)(1) Addition to Tax
Section 6651(a)(1) provides for an addition to tax in the
case of the failure to file a timely return unless it is shown
that such failure is due to reasonable cause and not due to
willful neglect. Petitioner bears the burden of proving that
respondent's determination on this issue is erroneous. Rule
142(a); Lee v. Commissioner, 227 F.2d 181, 184 (5th Cir. 1955),
affg. a Memorandum Opinion of this Court dated July 31, 1953. At
trial, petitioner testified that she did not timely file her 1987
Federal income tax return because she lacked the money to pay the
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