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We have found that petitioner did not file a tax return for
her taxable year 1994. In so finding, we rejected petitioner’s
self-serving and uncorroborated testimony that Mr. Ober filed a
tax return for that year on behalf of her.7
On the record before us, we find that petitioner has failed
to carry her burden of showing that her failure to file a tax
return for her taxable year 1994 was due to reasonable cause and
not due to willful neglect. On that record, we further find that
petitioner is liable for her taxable year 1994 for the addition
to tax under section 6651(a)(1).
Section 6654(a)
Section 6654(a) imposes an addition to tax in the case of an
underpayment of estimated tax by an individual.
We have found that petitioner did not make any estimated tax
payments for her taxable year 1994.8 Although it is not alto-
gether clear, it appears that petitioner may be arguing that she
is not liable for 1994 for the addition to tax under section
6654(a) because she is not required to include in gross income
7Although petitioner claimed at trial that she had a copy of
the tax return that Mr. Ober allegedly filed on her behalf for
her taxable year 1994, petitioner did not proffer such copy to
the Court. Nor did petitioner provide such copy to respondent.
Moreover, respondent has no record that petitioner filed a tax
return for her taxable year 1994. In fact, respondent prepared a
substitute for return for that year.
8Our finding about petitioner’s failure to make any esti-
mated tax payments for 1994 was based on the parties’ stipula-
tion.
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