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unreimbursed employee business deductions of $8,044 and $5,457
for 1990 and 1991, respectively.
Issue 5. Addition to Tax Under Section 6651(a)
Respondent determined an addition to tax under section
6651(a) for delinquent filing of a return.
Section 6651(a) provides that if a taxpayer fails to file a
return by its due date, including extensions of time for filing,
there shall be an addition to tax equal to 5 percent of the tax
required to be shown on the return for each month the failure to
file continues, not to exceed 25 percent.
Petitioner had an extension until June 15, 1991, to file his
1990 return. Petitioner did not file his 1990 return until July
1, 1992. Petitioner has failed to meet his burden on this issue.
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Accordingly, respondent's addition to tax on this issue is
sustained.
Issue 6. Penalty Under Section 6662(b)
Respondent determined that the portion of the underpayment
for 1990 attributable to the disallowance of the unreimbursed
employee business expenses was due to negligence.
Section 6662 provides for an accuracy-related penalty equal
to 20 percent of the portion of the underpayment due to
negligence. For purposes of section 6662, negligence "includes
any failure to make a reasonable attempt to comply with the ***
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