Anargyros George Mylonas - Page 6

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               In this case, petitioner has not demonstrated an absence of            
          fault.  Petitioner made an ill-informed decision to concentrate             
          on running his business while ignoring his tax-filing obligation.           
          Petitioner failed to take any steps to prepare or file his tax              
          return by the extended deadline.  At trial, petitioner explained            
          this failure by pointing out that he was "too busy to * * * do              
          everything."  Reflecting the wisdom of hindsight, petitioner                
          admitted at trial that, if he had known his failure to file his             
          return was going to cost him so much money, he would have closed            
          his business for a week and taken the steps necessary to file his           
          return on time.                                                             
               Petitioner's conduct and his justification of it do not                
          reflect the ordinary business care and prudence necessary to                
          establish reasonable cause under section 6651(a)(1).  Since                 
          petitioner has failed to show that his failure to file his return           
          for 1993 was due to reasonable cause, we hold that petitioner is            
          liable for the addition to tax under section 6651(a)(1) for 1993.           
               To reflect the foregoing and concessions set forth in the              
          stipulations of the parties,                                                

                                                  Decision will be entered            
                                             in accordance with this                  
                                             opinion and the stipulations             
                                             of the parties.                          

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