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4. Additions to Tax--Irene
Respondent determined that Irene filed a delinquent return
for the taxable year 1988 and that she is liable for an addition
to tax under section 6651(a). Section 6651(a) imposes an
addition to tax for failure to file a timely return unless such
failure is due to reasonable cause. Because we hold that Irene
received alimony required to be included in her gross income in
1988 and she has failed to show reasonable cause for the delin-
quent filing of her return, she is liable for an addition to tax
under section 6651(a) for 1988.
Respondent determined that Irene is liable for an addition
to tax under section 6661(a) for a substantial understatement of
tax for the taxable year 1988 and for accuracy-related penalties
under section 6662(b)(2) for substantial understatements of tax
for the taxable years 1989 and 1990.
Section 6661(a) provides for an addition to tax if there is
a substantial understatement of income tax.
Section 6661(c) authorizes the Commissioner to waive all or
any part of this addition to tax on a showing by the taxpayer
that there was reasonable cause for the understatement (or part
thereof) and that the taxpayer acted in good faith.
Section 6662(a) and (b)(2) provides for an accuracy-related
penalty if there is a substantial understatement of tax. Section
6664(c) provides that the section 6662 penalty is not imposed if
it is shown that the taxpayer had reasonable cause for the
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