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distribution in 2000 at the insistence of Mr. Barrera, and we
thus recognize Mr. Barrera’s influence with respect to this
income. Ultimately, though, petitioner agreed to Mr. Barrera’s
request for the distribution because she knew that she and her
family needed the money or, as she testified, she would “end up
under a bridge”, and she further knew there would be tax
consequences to the distribution.
We next note that the unpaid additions to tax and interest
for taxable years 1998 and 1999 are the result of petitioner and
Mr. Barrera’s failure to timely file their joint income tax
returns, and the unpaid additions to tax and interest for those
years and for taxable year 2000 are the result of petitioner and
Mr. Barrera’s failure to pay their income taxes when they were
due. All taxpayers have a duty to file timely and accurate
returns and to pay the amounts shown as due on those returns.
See generally secs. 6001, 6011(a), 6012(a)(1), 6072(a), 6151(a).
Petitioner’s reliance on Mr. Barrera, therefore, to handle the
preparation and filing of their joint returns for taxable years
1998, 1999, and 2000 does not establish that the additions to
tax and interest for those years are solely attributable to Mr.
Barrera.
Under these circumstances, we find that the attribution
factor weighs somewhat in favor of relief for taxable years 1998
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