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records, however, substantiate business travel expenses beyond
those allowed by respondent. Begole testified generally to
petitioner’s work schedule and travel but did not offer specific
details that would adequately substantiate the claimed expenses.
Petitioner has not adequately substantiated travel expenses
other than those vehicle expenses and parking fees allowed by
respondent.
Addition to Tax and Penalties
Section 6651(a)(1) imposes additions to tax where taxpayers
fail to timely file income tax returns unless the failure is due
to reasonable cause. To establish reasonable cause, taxpayers
must show that they exercised ordinary business care and prudence
but were still unable to file their tax returns by the due dates.
Sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Whether the
untimely filing of tax returns is due to reasonable cause raises
a question of fact. Denenburg v. United States, 920 F.2d 301,
303 (5th Cir. 1991).
Petitioner cites “unusual” personal circumstances and
excessive work for DUI as the reasons for his lack of records and
his and Begole’s inability to timely file their 1993 income tax
return.
Petitioners have not established reasonable cause as to why,
with the help of their accountant, they were unable to file on
time their 1993 Federal income tax return. We sustain
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