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In the instant case, petitioner argues that the AMT does not
apply because the $37,767 bonus received from Dean Witter in 1991
that petitioner originally reported on his 1991 Federal income
tax return constituted "illusory" income that incorrectly was
included in his taxable income for 1991. If the $37,767 bonus
were excluded from his taxable income, the AMT would not be
triggered.
We have already concluded that the $37,767 bonus received by
petitioner in 1991 is includable in petitioner's taxable income.
We sustain respondent's determination with regard to the AMT.
1991 and 1992 Addition to Tax and Accuracy-Related Penalties
Section 6651(a) imposes an addition to tax for the failure
of taxpayers to timely file Federal income tax returns, unless
the failure is due to reasonable cause. Sec. 6651(a)(1).
Whether reasonable cause exists is a question of fact. United
States v. Boyle, 469 U.S. 241, 249 n.8 (1985). Reasonable cause
for failure to timely file tax returns may exist where taxpayers
prove that they exercised ordinary business care and prudence and
were nevertheless unable to file the returns within the
prescribed time. Sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
Filing extensions are taken into account in determining
whether tax returns are timely filed. Sec. 6651(a)(1). For an
extension to be valid, however, generally the amount of tax due
should be properly estimated and the estimated tax should be
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