Janet Phillips - Page 4

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          applicable statute and show that he comes within its terms"); cf.           
          sec. 1.162-1(a), Income Tax Regs. (stating that to be deductible,           
          business expenses must be "directly connected with or pertaining            
          to the taxpayer's trade or business" (emphasis added)).                     
          Accordingly, we hold that petitioner is not entitled to a                   
          deduction for NHR's business expenses.                                      
               Respondent determined that petitioner was liable for                   
          additions to tax for failure to file her Federal income tax                 
          returns in a timely manner as well as accuracy-related penalties            
          for negligence.                                                             
               Section 6651(a) imposes an addition to tax for failure to              
          file a tax return in a timely manner.  Petitioner's 1992 and 1993           
          tax returns were due on April 15, 1993 and 1994, respectively.              
          Petitioner did not file those returns, however, until October 14,           
          1994.  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.                            
               Section 6662 imposes an accuracy-related penalty on the                
          portion of an underpayment that is attributable to negligence or            
          disregard of rules or regulations.  Negligence is the "'lack of             
          due care or failure to do what a reasonable and ordinarily                  
          prudent person would do under the circumstances.'"  Neely v.                





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