Jane C. Barber - Page 10

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          return for 1992 so as to gain more time to assemble the                     
          information she claims to have needed in order to file.                     
               Moreover, petitioner admitted that, by late 1994, she had              
          obtained a sufficient number of the records to prepare a Federal            
          income tax return for 1992.  Accordingly, the delay in filing               
          subsequent to late 1994 cannot be attributed to the                         
          unavailability of records.                                                  
               Lastly, financial difficulties generally do not constitute             
          reasonable cause for failure to file a return.  Jones v.                    
          Commissioner, 25 T.C. 1100, 1106 (1956), revd. and remanded on              
          other grounds 259 F.2d 300 (5th Cir. 1958); Sanders v.                      
          Commissioner, 21 T.C. 1012, 1019 (1954), affd. 225 F.2d 629 (10th           
          Cir. 1955).  Petitioner stipulated that, inter alia, wages of               
          $59,484, pension and annuity income of $18,696, short-term                  
          capital gain of $57,012, and long-term capital gain from the sale           
          of a building of $121,556 are properly reportable by her for her            
          1992 taxable year.                                                          
               None of the circumstances on which petitioner relies                   
          justifies relief from the addition to tax provided by section               
          6651(a).  Rather, it appears to us that petitioner simply put the           
          filing of that return aside because of matters she considered               
          more pressing and took no steps to prepare her return until                 
          respondent acted to address her failure to file.  Indeed,                   
          petitioner indicated in her testimony that, although she                    






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