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estate broker.3 The two principal factors that lead the Court to
this conclusion are (1) the personal aspects of the trip, and (2)
that one leg of the trip (also the lengthiest), to Orlando, was
not related to petitioner husband's trade or business.
Accordingly, the Court holds that the $905 automobile rental
expense is not deductible by petitioners as a trade or business
expense. Respondent, therefore, is sustained on this issue.
The second issue is whether petitioners are liable for the
addition to tax under section 6651(a)(1) for their failure to
timely file a Federal income tax return. Section 6651(a)(1)
imposes an addition to tax for a taxpayer's failure to file a
timely return, unless the taxpayer can establish that such
failure "is due to reasonable cause and not due to willful
neglect". The addition to tax is 5 percent of the amount
required to be shown on the return for each month beyond the
return's due date, not to exceed 25 percent. Sec. 6651(a)(1).
Petitioners applied for, and received, two extensions of
time to file their 1993 Federal income tax return. The second
extension expired on October 15, 1994; however, petitioners did
not file their return until June 12, 1995. Petitioners contend
that their failure to timely file was due to reasonable cause
3
The Court notes further that, since petitioner wife's
expenses for the Orlando trip were fully reimbursed by her
employer, the automobile rental expense would not be deductible
as an unreimbursed employee expense incurred by her.
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