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primary focus was overseeing her brother’s caregiver needs and
starting a new business venture.
We accept petitioner’s testimony that she became responsible
for her brother after he was released from the hospital in 2003.
However, petitioner testified that she found the time to try to
start a new greeting card venture and also found caregivers for
her brother by May 2004, 5 months before the extended due date of
the 2003 tax return and more than 7 months before it was actually
filed.10 We conclude that petitioner failed to demonstrate that
her failure to file timely a return was because of reasonable
cause and not willful neglect. See sec. 301.6651-1(c), Proced. &
Admin. Regs. Accordingly, petitioner is liable for the addition
to tax under section 6651(a)(1) for 2003.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
10 We note that respondent did not determine a sec. 6651
addition to tax with regard to petitioner’s late filing of her
2002 return.
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