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and one or more of his representatives advised him not to file
the joint return for 1993 until the conclusion of the examination
of taxable years 1987 through 1990; and (4) he was caring for his
sick mother.
In support of his position regarding the late filing of the
1993 joint return in question, petitioner relies on his self-
serving testimony, on which we are not required to, and we shall
not, rely.108 Even if we had believed the excuses offered by
petitioner for his failure to file timely that return, on the
record before us, we find that those excuses are not adequate to
show reasonable cause for petitioner’s failure to file timely.109
107(...continued)
taxable years 1991 and 1992.
108With respect to petitioner’s claim that he relied on one
or more of his representatives, who advised him not to file the
1993 joint return until after the completion by respondent of the
examination of certain prior taxable years, petitioner did not
question Mr. Sutton and Mr. DiBernardo, or call Ms. Schwiff as a
witness, regarding what they advised him with respect to the
filing of that return. We infer from petitioner’s failure to
question Mr. Sutton and Mr. DiBernardo and to call Ms. Schwiff in
that regard that their testimony would not have been favorable to
petitioner’s contention that one or more of them advised him not
to file the 1993 joint return until after the conclusion of
respondent’s examination of certain prior taxable years. We also
note that Mr. DiBernardo first met petitioner in 1995, sometime
prior to the date (May 14, 1995) on which respondent received the
1993 joint return in question.
109With respect to petitioner’s claim that he did not file
timely the 1993 joint return because he was caring for his sick
mother, petitioner testified that his mother passed away on Aug.
20, 1994. However, respondent did not receive the 1993 joint
return until May 14, 1995. Petitioner did not explain how his
caring for his sick mother contributed to his not filing the 1993
joint return until almost 9 months after she died.
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