- 19 -
ing for that year.6 On the record before us, we reject peti-
tioner’s position.
Assuming arguendo that Form W-4 for 1987 had indicated that
full-time students were exempt from withholding for that year and
that petitioner was exempt from withholding for each of her
taxable years 1987, 1988, and 1989, on the record before us, we
find that petitioner was required to file timely a return for
each of those years and to pay timely the tax shown in each such
return. See sec. 6012(a)(1)(A).
On the record before us, we find that petitioner has failed
to show that her failure to file timely her return for each of
her taxable years 1987, 1988, and 1989 and her failure to pay
timely the tax shown in each such return was due to reasonable
cause and not to willful neglect. On that record, we find that
petitioner has failed to show that she is not liable for the
additions to tax under section 6651(a)(1) and (2) that respondent
assessed for each of those years.
6Although petitioner claims that, pursuant to Form W-4 for
1987, she was exempt from withholding for each of her taxable
years 1987, 1988, and 1989 because she was a full-time student
during each such year, tax was withheld from her wages during
each of those years, and petitioner was aware of such withhold-
ing. On the instant record, we find incredible petitioner’s
claimed belief that she was exempt from withholding. Even if
petitioner had erroneously believed that she was exempt from
withholding for each of the years 1987, 1988, and 1989, her
mistake as to, or ignorance of, the law does not constitute
reasonable cause under sec. 6651(a)(1) and (2). Joyce v. Commis-
sioner, 25 T.C. 13, 15 (1955).
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