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cause for his failure to file his 1987 return because he was
preoccupied, beginning sometime in March 1988 and continuing
through August 1988, with the disappearance of his mother while
in the custody of a New York City homeless shelter or hospital,
his subsequent search for her with inadequate assistance from the
authorities or other family members, and his ultimate discovery
in August 1988 that she had died and been buried unclaimed.
Further, arrangements were protracted for her exhumation,
funeral, and reburial, which did not occur until October 1988 due
to demands of other family members. Even if we accept
petitioner's chronology, the foregoing events do not constitute
reasonable cause for his failure to file, because the failure
continued well after the traumatic events which he cites. The
incapacity of a taxpayer due to his illness or the illness of an
immediate family member may constitute reasonable cause for a
delay in filing a return. Williams v. Commissioner, 16 T.C. 893,
906 (1951); Tabbi v. Commissioner, T.C. Memo. 1995-463; Hayes v.
Commissioner, T.C. Memo. 1967-80. However, the duration of the
incapacity must approximate that of the failure to file. See,
e.g., Tabbi v. Commissioner, supra (reasonable cause where late
return not filed until 2 months after taxpayers' child's death);
Hayes v. Commissioner, supra (taxpayers' and their children's
illnesses during first half of year was reasonable cause for late
return not filed until August of that year); see also Barber v.
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