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We do not find that such circumstances constitute reasonable
cause which would justify petitioner's failure to timely file her
1992 return. Cf. Estate of Bevan v. Commissioner, T.C. Memo.
1989-256. On this record, we conclude that petitioner failed to
demonstrate that she exercised ordinary business care and
prudence. There is no evidence in the record that petitioner
took any measures to ensure that her 1992 return would be timely
filed. Accordingly, we sustain respondent on this issue.
To the extent our findings above affect petitioner's self-
employment tax and its corresponding deduction, and the Schedule
A deductions, the parties shall address this in their Rule 155
computations.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011