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find that excuse for petitioner's failure to file timely his 1991
and 1992 returns to be reasonable cause for purposes of section
6651(a)(1).6
Based on our review of the entire record in this case, we
find that petitioner has not satisfied his burden of proving that
his failure to file timely his 1991 and 1992 returns was due to
reasonable cause and not due to willful neglect. See United
States v. Boyle, supra; Estate of Vriniotis v. Commissioner,
supra. Accordingly, we find that petitioner is liable for the
additions to tax under section 6651(a)(1) for 1991 and 1992.7
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
5(...continued)
to file a return and yet will not be liable for the addition to
tax under sec. 6651(a)(1). We disagree.
6 Moreover, contrary to the suggestion of petitioner, on the
instant record, we find that he had adequate time within which to
obtain duplicate copies of, or otherwise to reconstruct, contrac-
tor receipts relating to his wife's catering activities.
7 The amounts of such additions to tax, which must take into
account the concessions of the parties on other issues, shall be
determined by the parties in the Rule 155 computation.
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