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reasonable cause for failing timely to file. In each instance,
petitioner filed for an extension to file, but failed to file
before the extended time. Petitioner was aware of her filing
obligations, and, as a lawyer, it would be difficult for her to
claim otherwise. In spite of her personal difficulties, she was
able to conduct her law practice and horse activity. Although we
can agree that petitioner experienced hardships and had much
responsibility, we are unable to find that she had reasonable
cause for failing to timely file. In similar situations of
deaths in the family, e.g., Radde v. Commissioner, T.C. Memo.
1997-490, and the press of work of a solo practitioner/doctor,
Polsby v. Commissioner, T.C. Memo. 1998-459, we have held that
the delinquency addition or penalty can apply. Petitioner here
is no different. Petitioner’s failure-to-file pattern was
lengthy and consistent and preceded and continued after the
difficulties presented by petitioner’s mother’s condition and
death. Accordingly, we sustain respondent’s determination that
petitioner is liable for the additions to tax under section
6651(a)(1) for the years determined.
To reflect the foregoing,
Decision will be entered under
Rule 155.
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