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to file, or ratify the filing of a petition for his 1980 tax
year. Thus, we lack jurisdiction over petitioner’s 1980 tax
year. Consequently, we lack jurisdiction to decide whether the
time for respondent to assess petitioner’s 1980 tax liability has
passed.
B. Whether Petitioner Had Reasonable Cause To File His 1981
Return Late
Petitioner contends that he had reasonable cause to file his
1981 income tax return late because he was at sea for up to 6
months in 1982 and he lived in Maryland rather than Colorado
where the Synergy Resources project was based. We disagree.
A taxpayer is liable for an addition to tax of up to 25
percent for failure to timely file Federal income tax returns
unless the taxpayer shows that such failure was due to reasonable
cause and not willful neglect. See sec. 6651(a)(1). To prove
reasonable cause, a taxpayer must show that he or she exercised
ordinary business care and prudence and was nevertheless unable
to file the return within the prescribed time. See Crocker v.
Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-1(c)(1),
Proced. & Admin. Regs. Petitioner reentered the Navy in June
1982. He has not shown that being at sea or living in Maryland
prevented him from timely filing his 1981 return. We conclude
that petitioner has not shown that he had reasonable cause to
file his 1981 return late.
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