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adequately disclosed in the return or in a statement attached to
the return. Sec. 6661(b)(2).
Petitioners have failed to meet their burden of proof on
this issue. The record does not disprove respondent’s
determination that the understatements are substantial, and it
does not establish that any of the understatements are reduced
under section 6661(b)(2). We sustain respondent’s determination.
4. Delinquency--Section 6651(a)(1)
Respondent determined an addition to tax under section
6651(a)(1) for Mrs. Sparrow’s 1986 and 1988 taxable years,
asserting that she failed to file timely Federal income tax
returns. In order to avoid this addition to tax, Mrs. Sparrow
must prove that her failure to file was: (1) Due to reasonable
cause and (2) not due to willful neglect. Sec. 6651(a);
Rule 142(a); United States v. Boyle, 469 U.S. 241, 245 (1985);
Catalano v. Commissioner, 81 T.C. 8 (1983). A failure to file
timely is due to reasonable cause if the taxpayer exercised
ordinary business care and prudence, and, nevertheless, was
unable to file the return within the prescribed time. Sec.
301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect means a
conscious, intentional failure or reckless indifference.
United States v. Boyle, supra at 245.
Petitioners filed their 1986 and 1988 Forms 1040 on
October 12, 1988, and October 17, 1990, respectively, and they
did so without the benefit of any extensions to the statutory
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