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despite the poor health of Bauman’s father, Bauman managed to
continue his practice of law. This ability to continue managing
his normal affairs, respondent contends, indicates that Bauman
was not so overwhelmed by his concern for his father that he
could not comply with his obligation to file the tax return.
Respondent also argues that Bauman’s concern for his father did
not preclude Mrs. Bauman from fulfilling their obligation to file
a timely return. We agree with respondent.
Petitioners have not established that their failure to file
their 1982 tax return by the prescribed date was due to
reasonable cause and not due to willful neglect. While we
appreciate the emotional difficulties Bauman may have experienced
while caring for his father, the record does not support his
contention that he was so overwhelmed by his father’s
deteriorating health as to preclude a timely filing. The fact
that Bauman continued to practice law throughout this period
indicates that his father’s condition did not prevent him from
filing the return on time. See Dickerson v. Commissioner, T.C.
Memo. 1990-577. Moreover, petitioners failed to explain why Mrs.
Bauman was unable to satisfy the couple’s obligation to file a
timely return.
We reject petitioners’ contention that the late filing
addition to tax should not be applied to them merely because
their return was in fact filed prior to the expiration of the 4-
month extension period that would have been granted automatically
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