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petitioner's employment. Therefore, we sustain respondent on
this issue.
Addition to Tax for Failure To Timely File Under Section 6651(a)
Respondent determined that petitioner was liable for an
addition to tax for failure to timely file a tax return for 1991.
Generally, taxpayers failing to submit a timely return are
subject to this addition to tax, unless they establish that the
failure resulted from "reasonable cause" and not from "willful
neglect". United States v. Boyle, 469 U.S. 241, 245-246 (1985).
Petitioner filed his return for the 1991 tax year on December 28,
1993, but noted at trial that he was preoccupied with other
matters at the time his return was due. The fact that a taxpayer
is busy during the time that his or her return is due does not,
by itself, establish reasonable cause for failing to timely file
a return. Dustin v. Commissioner, 467 F.2d 47, 50 (9th Cir.
1972), affg. 53 T.C. 491 (1969). Therefore, we sustain
respondent on this issue.
Accuracy-Related Penalty Under Section 6662(a)
For 1990 and 1991, respondent determined that petitioner is
liable for the accuracy-related penalty provided under section
6662(a). The accuracy-related penalty is equal to 20 percent of
any portion of an underpayment attributable to a taxpayer's
negligence or disregard of rules or regulations. Sec. 6662(a)
and (b)(1). The term "negligence" includes any failure to do
what a reasonable and ordinarily prudent person would do under
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