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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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