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petitioner provided no information demonstrating the extent to
which Ms. Felton’s family loss prevented the corporation from
filing its return. See Tokarski v. Commissioner, 87 T.C. at 77.
On the basis of the record before us, we therefore conclude that
petitioner did not demonstrate that its failure to timely file a
return was due to reasonable cause and not willful neglect. See
sec. 301.6651-1(c), Proced. & Admin. Regs.; sec. 1.6161-1(b),
Income Tax Regs. Accordingly, petitioner is liable for the
addition to tax under section 6651(a)(1) for 2002.
Conclusion
We have considered all of the other arguments made by
petitioner, and, to the extent that we have not specifically
addressed them, we conclude that they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues,
Decision will be entered
for respondent as to the
deficiencies in tax and the
addition to tax under section
6651(a)(1) for 2002 in the
amount of $1,116.60.
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