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F.2d 1521, 1527 (10th Cir. 1989), affg. 86 T.C. 492 (1986);
Crocker v. Commissioner, 92 T.C. 899, 912 (1989).
Petitioner may demonstrate reasonable cause for late payment
by showing that he exercised ordinary business care and prudence
in providing for payment of his tax liability and was
nevertheless either unable to pay the tax or would suffer an
undue hardship if he paid the tax by the due date. Sec.
301.6651-1(c), Proced. & Admin. Regs.; see United States v.
Boyle, supra at 246. To constitute “undue hardship”, the
hardship must be more than an inconvenience to the taxpayer, and
it must appear that substantial financial loss would result to
the taxpayer from making payment by the due date. Sec. 1.6161-
1(b), Income Tax Regs. “Willful neglect” is defined as a
“conscious, intentional failure or reckless indifference.”
United States v. Boyle, supra at 245.
At the time that petitioner filed his returns, he failed to
remit the amount shown as tax. Petitioner contends that he did
not remit payment for the years in issue because of financial
hardship due to his personal expenses related to his divorce and
child support payments and his business expenses. Specifically,
petitioner argues that he had substantial legal bills and that
his business was struggling. Although we are mindful that his
personal and business circumstances constrained his financial
resources, petitioner has nevertheless failed to establish that
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