William H. Breucher III - Page 17

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               Bruecher Foundation’s tax return for taxable year ending               
          March 31, 2000, was filed more than 8 months after the due date             
          of June 15, 2000.  Bruecher Foundation claims that its failure to           
          file its return in a timely manner was due to reasonable cause in           
          that Bruecher Foundation relied on its accountant to file a                 
          request for an extension for such tax return.  Mr. Bruecher                 
          testified that his accountant, Richard Heiling (Mr. Heiling),               
          usually filed for extensions for Bruecher Foundation returns and            
          that he believed Mr. Heiling had done so for taxable year ended             
          March 31, 2000.  However, Mr. Bruecher failed to produce any                
          evidence that an extension request was filed or that his reliance           
          was reasonable.  Accordingly, although Bruecher Foundation has              
          provided a reason for failing to timely file, it has not provided           
          a reason for which its failure to file can be excused.                      
          3.   Conclusion                                                             
               We have considered all of the other arguments made by the              
          parties, and, to the extent that we have not specifically                   
          addressed them, we conclude they are without merit.                         
               Reviewed and adopted as the report of the Small Tax Case               
                                             Decisions will be entered                
                                        for respondent.                               

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