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access to her belongings prior to January 2000. While living in
temporary housing, her belongings were in storage.
We conclude that respondent has produced sufficient evidence
indicating that petitioner failed to file her return timely and
the application of section 6651(a)(1) is appropriate. We also
conclude that petitioner has not demonstrated that her failure to
file the return timely was due to reasonable cause. Accordingly,
respondent’s determination is sustained.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011