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We hold that petitioner’s explanation of a cash hoard
(nontaxable source) is not credible and is insufficient to show
that respondent’s determination of unreported income is in error.
Accordingly, respondent’s determination, after concessions, is
sustained.
Is petitioner liable for additions to tax for filing
delinquent returns (section 6651(a)(1)) for the 1986, 1989, 1990,
1991, and 1992 taxable years? Respondent determined that
petitioner is liable for the additions to tax under section
6651(a)(1) for her failure to timely file Federal income tax
returns. Section 6651(a)(1) provides for an addition to tax of 5
percent of the tax required to be shown on the return for each
month or fraction thereof for which there is a failure to file,
not to exceed 25 percent. The addition to tax for failure to
file a timely return is imposed unless the taxpayer shows that
the delay was due to reasonable cause and not willful neglect.
See sec. 6651(a)(1); United States v. Boyle, 469 U.S. 241, 245
(1985). A failure to file is due to “reasonable cause” if the
taxpayer exercised ordinary business care and prudence and was,
nevertheless, unable to file the return within the time
prescribed by law. See United States v. Boyle, supra at 246.
Petitioner contends that the difficulties in her life,
including her mother’s illness and her obligations as a solo
practitioner of law, caused turmoil in her life and constitute a
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