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4. Laundry Expense
With respect to her 1994 tax year, petitioner deducted $596
for professional laundry expense on her Schedule C. Respondent
determined that petitioner was entitled to a deduction of $260
for such expense. Petitioner did not introduce evidence
supporting a deduction in excess of that determined by
respondent. Accordingly, respondent’s determination in this
regard is sustained.
C. Additions to Tax and Penalties
1. Section 6651(a)
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a tax return. The addition equals 5 percent of the
amount of tax required to be shown on the return for each month
the return is late, not to exceed 25 percent in the aggregate.
The addition to tax under section 6651(a)(1) is imposed unless
the taxpayer establishes that such failure “is due to reasonable
cause and not due to willful neglect”.
Petitioner failed to timely file her 1992 and 1994 tax
returns. She contends that such failure is excusable on the
ground that she believed that she had a zero tax liability for
each year. Reasonable cause for delinquent filing exists if the
taxpayer demonstrates that she exercised ordinary business care
and prudence and nonetheless was unable to file the return within
the prescribed period. See United States v. Boyle, 469 U.S. 241,
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