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permits petitioner to exclude from her gross income for 1983,
1984, and 1985 a portion of the income that was paid to and/or
earned by Mr. Hardy during those years. On that record, we
sustain (1) respondent's position that petitioner has unreported
income of $24,132.19 for 1983, (2) respondent's determination, as
reduced on brief, that petitioner has unreported income of
$11,493 for 1984, and (3) respondent's determination that peti-
tioner has unreported income of $14,842 for 1985.
Additions to Tax
Section 6651(a)(1)
Respondent determined that petitioner is liable for each of
the years at issue for the addition to tax under section
6651(a)(1) because she failed to file a return for each such
year. The addition to tax under section 6651(a)(1) does not
apply if it is shown that the failure to file was due to reason-
able cause, and not due to willful neglect.
Although petitioner's position is not altogether clear, she
appears to contend that her failure to file a return was due to
reasonable cause, and not willful neglect, because she did not
know, and Mr. Hardy never informed her, that she had to report
and pay tax on a portion of the income that was paid to and/or
earned by him during the years at issue.
On the instant record, we reject petitioner's contention.
Petitioner was aware that Mr. Hardy was employed in the construc-
tion industry during the years at issue, and Mr. Hardy used at
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