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to a maximum of 25 percent of the tax. See id.
The addition is applicable for each year unless petitioner
establishes that her failure to file was due to reasonable cause
and not willful neglect. See id. If petitioner exercised
ordinary business care and prudence and was nonetheless unable to
file her return within the date prescribed by law, then
reasonable cause exists. See sec. 301.6651-1(c)(1), Proced. &
Admin. Regs. “Willful neglect” means a “conscious, intentional
failure or reckless indifference.” United States v. Boyle, 469
U.S. 241, 245 (1985).
Petitioner’s 1991 Federal income tax return was due on April
15, 1992. Petitioner filed a blank return with an application
for extension on June 5, 1992. Petitioner filed her 1991 and
1992 Federal income tax returns in June 1994. She contends that
the late filing of her 1992 return was a result of waiting for
the completion of the 1991 return.
Petitioner has failed to show that she exercised ordinary
business care and prudence in this case. Respondent is sustained
on this issue.
H. Section 6662(a)
The last issue for decision is whether petitioner is liable
for accuracy-related penalties pursuant to section 6662(a) for
the years in issue. Section 6662(a) imposes a penalty of 20
percent of the portion of the underpayment which is attributable
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