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6651(a)(1) addition to tax, either in her testimony or on brief.
Consequently, we have no basis on which to conclude that
petitioner’s failure to timely file her return was due to
reasonable cause and not due to willful neglect. We thus hold
that petitioner is liable for the section 6651(a)(1) addition to
tax as determined by respondent.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008