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taxpayer from filing his or her return. See, e.g., Hobson v.
Commissioner, T.C. Memo. 1996-272 (reasonable cause was found
where taxpayers cared for a seriously ill child and an invalid
parent and taxpayer husband’s job forced taxpayers to live apart
for part of the year); Tabbi v. Commissioner, T.C. Memo. 1995-463
(reasonable cause was found where taxpayers’ son had heart
surgery and taxpayers spent 4 months continuously in the hospital
with him, and taxpayers filed their return 2 months after their
son’s death). In contrast, a taxpayer generally does not have
reasonable cause for his or her failure to timely file a return
where the taxpayer’s illness does not prevent the taxpayer from
filing his or her return. See, e.g., Watts v. Commissioner, T.C.
Memo. 1999-416 (reasonable cause was not found where, although
taxpayer’s mother and daughter were both ill and taxpayer
frequently took them to see doctors, taxpayer also performed
extensive architectural services in taxpayer’s business); Wright
v. Commissioner, T.C. Memo. 1998-224 (reasonable cause was not
found where the taxpayer had capacity to attend to matters other
than filing tax returns despite his mother’s traumatic
disappearance and death and the taxpayer’s failure to file
returns continued beyond the duration of these events), affd.
without published opinion 173 F.3d 848 (2d Cir. 1999).
Although the Court sympathizes with Ms. Felton for the loss
of her mother, petitioner clearly filed its return beyond the
duration of the illness and incapacity, and, in the instant case,
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