Charlie Daniel Turner, Jr. and Sandra Lovell Turner - Page 16

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          inability to meet his or her tax obligations when he or she can             
          carry on normal activities does not excuse a late filing.”                  
          Respondent’s imposition of the addition to tax under section                
          6651(a)(1) for 1995 is sustained.                                           
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                           entered for respondent.                    

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