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reasons for his failure to timely file, such as inability to
assimilate records or information fast enough, an overworked
accounting staff, and computer inefficiencies were not reasonable
cause for not filing. See id. In re Craddock does not support
petitioners’ position in this case.
Petitioners also rely on Tabbi v. Commissioner, T.C. Memo.
1995-463. We disagree that it is analogous. Unlike what
occurred in the instant case, the taxpayers in Tabbi were in the
hospital with their son continuously for 4 months (ending in his
death) around the time that their return was due. In contrast,
neither petitioner’s mother nor petitioners’ daughter was
hospitalized for a prolonged period in 1994 and 1995. Despite
the fact that petitioner frequently took his mother and daughter
to see doctors, he also performed an extensive amount of
architectural services during the years in issue. His mother
died on March 28, 1996, but petitioners’ 1995 return was not due
until August 15, 1996. The fact that he was actively engaged as
an architect suggests that he would have been able to file timely
returns for 1994 and 1995 and therefore that he lacked reasonable
cause for his failure to do so. See Merriam v. Commissioner,
T.C. Memo. 1995-432 (taxpayer is not excused from filing timely
returns because he is overworked), affd. 107 F.3d 877 (9th Cir.
1997); Fambrough v. Commissioner, supra (although the taxpayer
cared for his sick wife and brother during the years in issue,
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