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petitioner was not a party. These documents have little, if any,
probative value bearing on petitioner's failure to file returns.
Moreover, even if petitioner relied on the substantive advice of
an attorney, it is entirely unnecessary to be a "tax expert to
know that tax returns have fixed filing dates and that taxes must
be paid when they are due." United States v. Boyle, supra at
251.
While petitioner may have honestly believed that she did not
have to file tax returns, that belief was not reasonable.
Petitioner has not shown that her failure to file returns for the
years at issue was due to reasonable cause. Accordingly,
petitioner is liable for additions to tax under section
6651(a)(1) in 1992 and 1993.
Section 6654 imposes an addition to tax for failure to make
estimated tax payments. Where prepayments of tax, either through
withholding or quarterly estimated tax payments during the course
of the year, do not equal the percentage of total liability
required to be paid as estimated tax, the addition is
automatically imposed unless the taxpayer proves that one of
several statutory exceptions applies. Sec. 6654; Habersham-Bey
v. Commissioner, 78 T.C. 304, 319-320 (1982); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner has made no
such showing and is liable for section 6654 additions to tax in
1992 and 1993.
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