Alice Pauline Browne, A.K.A. A. Pauline Browne - Page 6

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          expenses under the Cohan rule.  Vanicek v. Commissioner, supra.             
          Therefore, we hold that petitioner is not entitled to business              
          expense deductions for 1992 and 1993 in excess of the amounts               
          allowed by respondent.5                                                     
               The second issue for decision is whether petitioner is                 
          liable for the section 6651(a)(1) addition to tax for 1992.                 
               Section 6651(a)(1) imposes an addition to tax for failure to           
          timely file a return, unless the taxpayer establishes that such             
          failure is due to reasonable cause and not due to willful                   
          neglect.  "Reasonable cause" requires the taxpayer to demonstrate           
          that she exercised ordinary business care and prudence and was              
          nonetheless unable to file a return within the prescribed time.             
          United States v. Boyle, 469 U.S. 241, 245-246 (1985).  "Willful             
          neglect" means a conscious, intentional failure or reckless                 
          indifference.  Id. at 246.  The addition to tax equals 5 percent            
          of the tax required to be shown on the return if the failure to             
          file is for not more than 1 month, with an additional 5 percent             
          for each additional month or fraction of a month during which the           
          failure to file continues, not to exceed a maximum of 25 percent.           
          Sec. 6651(a)(1).                                                            
               Petitioner's 1992 return was originally due on April 15,               
          1993.  Sec. 6072(a).  She applied for and received an automatic,            



          5         We note that respondent allowed petitioner deductions             
          for substantial portions of her claimed expenses.                           




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