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that there was available to petitioner sufficient information to
prepare a timely return but that petitioner made no effort to do
so, and that financial difficulties do not excuse a failure to
file timely.
It is well established that incapacity on the part of a
taxpayer due to mental or physical illness is reasonable cause
for failure to file timely. Williams v. Commissioner, 16 T.C.
893, 906 (1951); Brown v. United States, 630 F. Supp. 57, 60
(M.D. Tenn. 1985); see also United States v. Boyle, supra at 248
n.6. A mental or emotional disorder, however, does not excuse a
failure to file timely unless it is shown that the disorder
rendered the taxpayer incapable of exercising ordinary business
care and prudence during the period that the failure to file
continued. Estate of Scull v. Commissioner, T.C. Memo. 1994-211;
Akins v. Commissioner, T.C. Memo. 1993-256, affd. without
published opinion 35 F.3d 577 (11th Cir. 1994); Farley v.
Commissioner, T.C. Memo. 1993-31. Moreover, a taxpayer's
selective inability to meet his or her tax obligations when he or
she can carry on normal activities does not excuse late filing or
failure to file. See Estate of McClanahan v. Commissioner, 95
T.C. 98, 101-102 (1990); Tabbi v. Commissioner, T.C. Memo. 1995-
463, and cases cited therein.
Although, in the instant case, petitioner experienced
emotional trauma as a result of the arrests of her husband, the
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