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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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