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not convinced us that we should disregard her stipulation or
trial testimony that she did not file a 1993 return. We conclude
that petitioner did not file a return for 1993.
A taxpayer is not liable for the addition to tax if his or
her failure to file a return was due to reasonable cause and not
willful neglect. Sec. 6651(a)(1); Rule 142(a); United States v.
Boyle, 469 U.S. 241, 245 (1985). Petitioner contends that, if
she did not file her 1993 income tax return, it was because she
had health difficulties in 1991 and 1992 or because she had a
difficult pregnancy in 1994. We disagree. Petitioner’s ability
to work full time in 1993 and 1994 shows that she should have
been able to file her return for 1993.
We conclude that petitioner is liable for the addition to
tax under section 6651(a) for failure to file her 1993 return.
D. Whether Petitioner Is Liable for the Addition to Tax for
Failure To Pay Estimated Tax in 1993
Respondent determined that petitioner is liable for the
addition to tax under section 6654 for failure to pay estimated
tax for 1993. Petitioner did not file a return for 1993. We
have jurisdiction to review the Commissioner’s determination of
this addition to tax if the taxpayer did not file a return for
the taxable year. Sec. 6665(b)(2); Meyer v. Commissioner, 97
T.C. 555, 562 (1991).
A taxpayer is liable for the addition to tax under section
6654 for failure to pay estimated tax unless the taxpayer shows
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