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is received by the Commissioner. Pryor v. Commissioner, T.C.
Memo. 1994-287.
Petitioner argues that reasonable cause existed with respect
to her failure to file a timely return because many of the
documents she needed to file the return were held by the court in
connection with her divorce proceedings. Despite petitioner's
assertion, the record reflects that petitioner's divorce
proceedings did not end until 1995, long after petitioner filed
her return in December 1993. Furthermore, petitioner could have
retained copies of the documentation related to her 1992 return
before submitting originals to the court which handled her
divorce matter. We conclude that petitioner is liable for the
addition to tax under section 6651(a).
We now turn to the calculation of the addition to tax. The
record contains petitioner's Form 4868, "Application for
Automatic Extension of Time To File U.S. Individual Income Tax
Return", dated April 12, 1993, in which petitioner requested an
extension to file until November 1, 1993. Pursuant to section
1.6081-4(a), Income Tax Regs., however, the automatic extension
is for a period of 4 months. The record does not contain a
request for an extension for an additional 3 months. Therefore,
petitioner's return was due on August 15, 1993.6 Since
6 We note that petitioner's request for an automatic
extension does not indicate any amount estimated as tax owed for
the taxable year. We have previously ruled that requests for
(continued...)
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