Fred Willie Thomas, Jr. - Page 7

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          issue because his then wife, Ora Mae Thomas, supported him,                 
          herself, and their daughter.  Based on the facts in the record,             
          however, we find this claim implausible.  The Bureau of Labor               
          Statistics indicate that a three-member household incurred                  
          average annual living expenses during 1987, 1988, and 1989 in the           
          respective amounts of $28,549, $30,446, and $32,643.  Ora Mae               
          Thomas earned wage income during 1987, 1988, and 1989 in the                
          respective amounts of $10,434.79, $5,705.21, and $12,762.00.                
          That she could support a three-member household on such a meager            
          income seems unlikely.                                                      
               Accordingly, we find that petitioner earned self-employment            
          income in the amounts determined by respondent for the years in             
          issue.                                                                      
          2.  Additions to Tax Under Section 6651(a)(1)                               
               Respondent determined an addition to tax under section                 
          6651(a)(1) for each year in issue, asserting that petitioner                
          failed to file Federal income tax returns.  In order to avoid               
          this addition to tax, petitioner must prove that his failure to             
          file was:  (1) Due to reasonable cause and (2) not due to willful           
          neglect.  Sec. 6651(a); United States v. Boyle, 469 U.S. 241, 245           
          (1985); In re Sanford, 979 F.2d 1511, 1512 (11th Cir. 1992).  A             
          failure to file a Federal income tax return 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.  In re Sanford, supra at 1514; sec.                    




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