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information demonstrating the extent to which her family’s
difficulties prevented her from filing the 2001 return at some
point before being “pounced upon” by the IRS.10
On the basis of the record before us, we therefore conclude
that petitioner did not demonstrate that her 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 2001.
Conclusion
After considering all of the facts and circumstances, we
hold that petitioner’s horse showing and breeding activities were
not engaged in for profit within the meaning of section 183 and
that she is also liable for the addition to tax under section
6651(a)(1) for her failure to timely file her 2001 tax return.
Reviewed and adopted as the report of the Small Tax Case
Division.
10 Given the stipulations in this case, a pattern emerges.
Petitioner did not file her Federal income tax return for the
taxable year 1999 until Sept. 17, 2001, well beyond the statutory
deadline of Apr. 15, 2000. See sec. 6072. Petitioner did not
file her Federal income tax return for the 2000 taxable year
until Oct. 11, 2001. At the time of trial, and despite having an
accountant with whom she regularly consulted, petitioner had not
yet filed her Federal income tax returns for taxable years 2002,
2003, 2004, and 2005.
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