Juanita Carter - Page 21

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          and requested she file another one, which she did.  Petitioner              
          claims that the March 16, 1992, filing date listed on the                   
          transcript of her 1989 tax year actually reflected the filing of            
          the copy of her return and did not reflect the date of her                  
          original filing of her 1989 return (which respondent allegedly              
          misplaced).  Petitioner produced no documentary evidence to                 
          support this allegation.  The Court is satisfied, on this record,           
          that March 16, 1992, is the original filing date of petitioner's            
          1989 Federal income tax return and that such return was not filed           
          timely.                                                                     
               Petitioner admits that the envelopes marked November 11,               
          1991, March 3, 1993, and August 17, 1993, reflected the actual              
          mailing dates of her returns for 1990, 1991, and 1992,                      
          respectively; however, she argues that various illnesses prior to           
          the due dates for each of these three returns incapacitated her             
          to a degree that she could not file timely her returns.                     
          Petitioner also contends that she requested and received an                 
          extension of time to file each of these three returns; however,             
          she failed to produce copies of such extensions at trial.                   
               Petitioner was in an automobile accident in March 1991 that            
          resulted in the spraining of her back; in 1992 she had                      
          conjunctivitis and her doctor "gave [her] the wrong medicine and            
          blinded [her]"; and, in 1993, she had another auto accident that            
          caused her additional physical pain.  In support of her claims,             





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