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official records of the Service that are part of the record in
this case show that petitioner did not file tax returns for any
of the years 1989 through 1992.3 We are not required to, and we
shall not, accept petitioner’s testimony that she timely filed
her tax returns for those years. See Geiger v. Commissioner, 440
F.2d 688, 689 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-
159; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
On the record before us, we find that petitioner has failed
to establish that she filed tax returns for the years 1989
through 1992. Accordingly, we hold that the respective periods
of limitations under section 6501 with respect to those years
have not expired.
Addition to Tax for Failure to File
Section 6651(a)(1) imposes an addition to tax for failure to
file a tax return on the date prescribed for filing. That
addition to tax does not apply if it is shown that the failure to
file was due to reasonable cause, and not due to willful neglect.
See sec. 6651(a)(1).
Petitioner contends that she is not liable for the additions
to tax under section 6651(a) for the years 1989 through 1992.4
3Service records also show that petitioner did not file a
tax return for 1993. See supra note 2 for petitioner’s conces-
sions regarding 1993.
4As we indicated supra note 2, petitioner concedes that she
is liable for the addition to tax under sec. 6651(a) for her
taxable year 1993.
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