Lloyd Patterson - Page 8

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          petitioner's deduction is subject to section 219(g).  Respondent            
          is wrong.  Petitioner is entitled to deduct his $2,000 IRA                  
          contribution in full.                                                       
               Petitioner, though he had income of at least $28,517 in                
          1991, did not timely file a Federal income tax return for 1991.             
          There was no extension requested by petitioner nor granted by the           
          Internal Revenue Service.  Petitioner's 1991 return was due on              
          April 15, 1992.  After the notice of deficiency was issued,                 
          petitioner submitted a signed Form 1040 for 1991 on February 8,             
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a Federal income tax return by its due date, determined with           
          regard to any extension of time for filing previously granted,              
          unless such failure was due to reasonable cause and not willful             
          neglect.  Fischer v. Commissioner, 50 T.C. 164, 177 (1968).                 
          Petitioner bears the burden of showing reasonable cause.  Fischer           
          v. Commissioner, supra.                                                     
               Petitioner presented no credible evidence as to why he                 
          failed to timely file a Federal income tax return for the year in           
          issue.  Respondent acknowledges that petitioner is entitled to a            
          withholding credit of $3,201.  Thus, we find that petitioner is             
          liable for an addition to tax under section 6651(a)(1) of 25                
          percent of the amount required to be shown on the return as tax             
          reduced by the $3,201 credit.                                               

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