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respect to her entitlement to the standard deduction in 1992.
Accordingly, respondent is sustained on this issue.
Additions to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return of 5 percent of the tax due for each month a
return is delinquent, not to exceed 25 percent. The addition
does not apply if the failure to timely file is due to reasonable
cause and not due to willful neglect. Sec. 6651(a)(1).
Petitioner has the burden of proving reasonable cause and the
lack of willful neglect. United States v. Boyle, 469 U.S. 241,
245 (1985); Baldwin v. Commissioner, 84 T.C. 859, 870 (1985). To
prove "reasonable cause", taxpayers must show they exercised
ordinary business care and prudence and were nevertheless unable
to file the return within the statutorily prescribed time.
Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-
1(c)(1), Proced. & Admin. Regs. Taxpayers may, generally,
establish reasonable cause by proving that they reasonably relied
on the advice of an accountant or attorney that it was
unnecessary to file a return and later found that such advice was
erroneous or mistaken. United States v. Boyle, supra at 250;
Estate of Paxton v. Commissioner, 86 T.C. 785, 820 (1986).
Petitioner contends that she had reasonable cause not to
file returns for 1992 and 1993 based on various tax protester
arguments described above. Petitioner also relies on the two IRS
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