Moti G. Bijlani - Page 5

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          bills, electric bills, and other living expenses.  After trial,             
          the record was reopened and petitioner submitted a document                 
          showing real estate tax expenses of $1,920.16 and mortgage                  
          interest expense of $215.77.                                                
               We find that petitioner did not prove that any of the                  
          claimed Schedule A deductions pertaining to his co-op were                  
          attributable to the management of his rental property.                      
          Unfortunately for petitioner, his personal expenses incurred in             
          connection with his co-op, where he resided, are nondeductible              
          personal living expenses.  Sec. 262(a).  We do not address the              
          restrictions under section 280A because this section was not                
          raised at trial.  Petitioner would be well advised to consult a             
          United States tax expert before filing future nonresident                   
          returns.                                                                    
               On this record, we have no choice but to conclude that                 
          petitioner has not established his entitlement to the claimed               
          Schedule A deductions.  Accordingly, we sustain respondent’s                
          determination on this issue.                                                
               Section 6651(a)(1) imposes an addition to tax for failure to           
          timely file a tax return, unless the taxpayer established that              
          failure to do so is due to reasonable cause and not willful                 
          neglect.  The taxpayer must prove both reasonable cause and lack            
          of willful neglect.  Crocker v. Commissioner, 92 T.C. 899, 912              
          (1989).  “Reasonable cause” requires the taxpayer to demonstrate            






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