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into account any extension of time for filing granted by respon-
dent. Sec. 301.6651-1(a)(1), Proced. & Admin. Regs.
Petitioner bears the burden of proving that reasonable cause
existed for such failure. Rule 142(a); United States v. Boyle,
469 U.S. 241, 245 (1985); Electric & Neon, Inc. v. Commissioner,
56 T.C. 1324, 1342 (1971), affd. without published opinion 496
F.2d 876 (5th Cir. 1974); Cepeda v. Commissioner, T.C. Memo.
1993-477, affd. without published opinion, 56 F.3d 1384 (5th Cir.
1995). Petitioner failed to timely file his 1987 Federal income
tax return. His 1987 Federal income tax return, due on Octo-
ber 15, 1988, owing to extensions, was not filed until August 16,
1990.
Petitioner asserts that the lateness of the return resulted
from a change from one accounting firm to another. Mr. Sweet
testified that he was not involved in preparing petitioner's
return for 1987. The record sheds virtually no light on why the
return was filed late.
Petitioner has failed to show that he exercised ordinary
business care and prudence in filing his 1987 Federal income tax
return. See United States v. Boyle, supra at 247.
Petitioner obtained a filing extension through October 16,
1989, for his 1988 Federal income tax return. Petitioner and
Mrs. Weigel filed their 1988 Federal income tax return on
October 11, 1990. Petitioner obtained no extensions for his 1990
Federal income tax return, which was due April 15, 1991.
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