Phyllis Herrmann Witcher - Page 13




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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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