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gospel. Tokarski v. Commissioner, supra. On this record, we
hold that petitioner is not entitled to a charitable contribution
deduction.
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on time. The addition is 5 percent for each month
that the return is late, not to exceed 25 percent. In order to
avoid the addition to tax under section 6651(a)(1), a taxpayer
must show both reasonable cause and a lack of willful neglect.
United States v. Boyle, 469 U.S. 241, 245 (1985). A failure to
file is due to "reasonable cause" if the taxpayer exercised
ordinary business care and prudence and was, nevertheless, unable
to file his return within the time prescribed by law. United
States v. Boyle, supra at 246. The term 'willful neglect'
implies a conscious, intentional failure to file or reckless
indifference to the obligation to file. United States v. Boyle,
supra at 245.
Petitioner filed her 1992 Federal income tax return on July
5, 1994. Petitioner contends that her failure to timely file her
1992 return was due to "the overwhelming nature of what has been
going on in her life." Petitioner asks the Court to take into
account her personal and professional circumstance, e.g., the
fact that she is a physician in solo practice, that her medical
career is in a state of turmoil, and that she was involved in
other litigation.
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