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petitioner retrieved her records in 1998, she failed to file her
income tax returns. The fact that petitioner has not filed her
returns even with full access to her records indicates a lack of
causal relationship between petitioner's failure to file and the
IRS's seizure of her business records.
Under these circumstances, we conclude that petitioner's
failure to file her 1991 and 1992 income tax returns was not due
to reasonable cause, and therefore the addition to tax is
properly imposed.
III. Addition to Tax Under Sec. 6654(a)
Respondent determined additions to tax for 1990 under
section 6654(a) for underpayment of estimated Federal income tax.
This addition to tax is mandatory absent a showing by petitioner
that one of the several statutorily provided exceptions applies.
See Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Petitioner has made no such showing. Respondent's determination
is therefore sustained.
To reflect the foregoing,
Decision will be
entered for respondent.
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