- 2 -
1988 50,029 12,507 3,198
1989 1,163 291 --
1990 34,767 8,692 2,290
After concessions by the parties, the only remaining issues are
whether petitioner is liable for the additions to tax set forth
below:
Additions to Tax
Year Sec. 6651(a) Sec. 6654
1987 $1,150 $280
1988 611 157
1990 1,186 --
At the time the petition was filed, petitioner resided in
Philadelphia, Pennsylvania. All section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Section 6651(a) imposes an addition to tax for failure to
file a tax return in a timely manner. Petitioner's tax returns
for 1987, 1988, and 1990 were due on April 15, 1988, 1989, and
1991, respectively. Petitioner, however, did not file such
returns until October 10, 1997. Petitioner has failed to
establish that her tardiness was due to reasonable cause and not
due to willful neglect. Sec. 6651(a); United States v. Boyle,
469 U.S. 241 (1985); Welch v. Helvering, 290 U.S. 111, 115
(1933). Accordingly, petitioner is liable for the section
6651(a) additions to tax.
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