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6651(a)(1) imposes an addition to tax for a taxpayer's failure to
file timely returns, unless the taxpayer can establish that such
failure "is due to reasonable cause and not due to willful
neglect". Petitioner did not file Federal income tax returns for
1988, 1989, and 1990. Petitioner's 1991 and 1992 Federal income
tax returns were due to be filed on or before April 15, 1992, and
1993, respectively. These returns were filed in October 1993.
Petitioner did not establish that her failure to file timely
Federal income tax returns for 1988 through 1993 was due to
reasonable cause and not due to willful neglect. Petitioner's
position is that she did not file income tax returns for 1988,
1989, and 1990 because she believed that the net operating loss
carryforwards from prior years would have negated any income tax
liabilities for the years 1988 through 1990. Petitioner
conceded, however, that she realized gross income in these 3
years. Her erroneous belief that no taxes are due does not
constitute reasonable cause for the failure to file an income tax
return. Krieger v. Commissioner, T.C. Memo. 1993-347.
Petitioner advanced no reasons why her income tax returns for
1991 and 1992 were not filed timely. Respondent, therefore, is
sustained on the addition to tax under section 6651(a)(1).
The next addition to tax is under section 6654(a) for
failure to pay estimated taxes for 1988 and 1990. Section
6654(a) provides for an addition to tax "in the case of any
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