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B. Expenses
Petitioner argues that she has additional rental activity
expenses beyond those allowed by respondent. Simply put,
petitioner has failed to prove deductible amounts in excess of
those allowed by respondent. Petitioner failed to produce books
and records detailing her real estate activities. The purpose of
certain checks presented to us by petitioner is unclear.
Petitioner has failed to prove rental activity related deductions
in excess of those allowed by respondent. Respondent’s
determination of deficiencies in that respect is sustained.
VI. Additions to Tax
A. Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return, unless it is shown that such failure is due
to reasonable cause and not due to willful neglect. Petitioner
bears the burden of proof as to reasonable cause and the absence
of willful neglect. See Rule 142(a).
Respondent has determined section 6651(a)(1) additions for
each of the years in issue. As a defense to the section
6651(a)(1) additions, petitioner relies on our finding no
deficiencies in tax. Except with respect to concessions made by
respondent, we have sustained respondent’s determinations of
deficiencies. Moreover, petitioner has failed to prove
reasonable cause and lack of willful neglect. Respondent’s
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