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motive. In contrast, realizing a profit would be indicative of
such a motive. However, on the record before us, we find that
petitioner did not realize a profit from his cattle activity for
1990 or 1991. On that record, we are unable to determine whether
he realized a profit from that activity for 1992, 1993, and 1994.
Based on our review of the entire record before us, we find
that petitioner has failed to establish that during 1990 and 1991
his cattle activity was an activity engaged in for profit within
the meaning of section 183. Accordingly, we sustain respondent's
determinations that the deductions that petitioner claimed for
1990 and 1991 relating to his cattle activity are limited by
section 183(a) and (b).
Additions to Tax and Accuracy-Related Penalties
Section 6651(a)(1)
Respondent determined that petitioner is liable for each of
the years 1989 and 1990 for the addition to tax under section
6651(a)(1) because he failed to file timely his return for each
such year. For purposes of section 6651(a)(1), the determination
of the prescribed date for filing a return must be made by
reference to any extension of the time for filing the return.
The addition to tax under section 6651(a)(1) does not apply if it
is shown that the failure to file was due to reasonable cause,
and not willful neglect. In order to prove reasonable cause, the
taxpayer must show that, despite the exercise of ordinary busi-
ness care and prudence, he or she was nevertheless unable to file
the return within the prescribed time. United States v. Boyle,
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