Karan M. Hintze - Page 21

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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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