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hardship”. Although we sympathize with petitioner over his
father’s ill health and the loss of his mother, a death in the
family some 9 months before the filing date generally does not
constitute reasonable cause for failing to file tax returns. See
Hastings v. Commissioner, T.C. Memo. 1999-167; Radde v.
Commissioner, T.C. Memo. 1997-490.
Additionally, the ability to continue performing daily
business operations negates grief as a reasonable cause. See
Dickerson v. Commissioner, T.C. Memo. 1990-577; Fambrough v.
Commissioner, T.C. Memo. 1990-104. Despite petitioner’s grief,
he continued his employment as wagon master on the wagon train.
Also, petitioner filed returns for 1995 and 1997, irrespective of
the logistical difficulties he faced while traveling on the wagon
train. We find that petitioner did not have reasonable cause for
the failure to file his 1996 return, and respondent’s
determination as to the addition to tax under section 6651(a)(1)
is sustained.
Addition to Tax Under Section 6654(a) for Failure To Pay
Estimated Tax
Section 6654(a) provides for an addition to tax “in the case
of any underpayment of estimated tax by an individual”. This
addition to tax is mandatory unless petitioner shows that one of
the statutorily provided exceptions applies. See sec. 6654(e);
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). There is
no exception for reasonable cause or lack of willful neglect.
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