Forrest Jackson - Page 13




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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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