Medical Emergency Care Associates, S.C., An Illinois Corporation - Page 16

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          under section 530 based, in part, on the fact that the debtor did           
          not timely file the required tax forms).  Rev. Proc. 85-18,                 
          however, provides no reason why it requires timely filing.  Thus,           
          we are unable to ascertain the thoroughness of the agency’s                 
          consideration or the validity of its reasoning.  Consequently, we           
          do not defer to its requirement of timely filing as a                       
          prerequisite to section 530 relief in this case.                            
               We conclude that petitioner’s untimely filing of information           
          returns does not preclude petitioner from qualifying for relief             
          pursuant to section 530(a).                                                 
          IV.  Reasonable Cause for Delinquent Filing                                 
               Petitioner argues that if section 530(a)(1)(B) requires                
          timely filing, that section should also provide a reasonable                
          cause exception to the timely filing requirement.  Petitioner               
          claims to have made “a serious effort to overcome delinquencies             
          that occurred in the wake of great personal crisis and loss [the            
          illness, and subsequent death, of Neena Mitchell], and                      
          ineffective accounting representation.”  Since we conclude that             
          section 530(a)(1)(B) does not prevent petitioner from obtaining             
          section 530 relief, we need not consider this argument.                     

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