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this Court bears petitioner's signature dated August 14, 1996,
and Mr. Williams’ signature dated August 12, 1996. Therefore, by
petitioner's own admission, the earliest petitioner could have
mailed her 1995 return would have been mid-August 1996, at least
4 months late. Additionally, petitioner did not have personal
knowledge of the mailing of her 1995 return and could not produce
a certified mailing receipt for her 1995 return.
On the basis of the record, we find that petitioner has not
established that her failure to timely file her Federal income
tax return for the 1995 tax year was due to reasonable cause and
find that petitioner's 1995 return was filed more than 4 months
late. Therefore, we hold that petitioner is liable for the
maximum 25 percent of the addition to tax under section
6651(a)(1) for 1995. Respondent is sustained on this issue.
4. Additions to Tax for Failure To Pay Estimated Income Taxes
Section 6654(a) imposes an addition to tax where prepayments
of tax, either through withholding or estimated quarterly tax
payments during the year, do not equal the percentage of total
liability required under the statute. However, the addition to
tax is not imposed if the taxpayer can show that one of several
statutory exceptions applies. See sec. 6654(e). Petitioner has
not contended that she qualifies for any of the exceptions.
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