                           T.C. Memo. 1998-48



                        UNITED STATES TAX COURT



                 JUDITH WEINGARTH FOX, Petitioner v.
            COMMISSIONER OF INTERNAL REVENUE, Respondent



       Docket No. 16226-96.                     Filed February 9, 1998.



       Judith Weingarth Fox, pro se.

       Michael D. Baker, for respondent.



                           MEMORANDUM OPINION


       FOLEY, Judge:   Respondent determined the following

deficiencies in and additions to petitioner's Federal income

taxes:


                                      Additions to Tax
Year          Deficiency       Sec. 6651(a)       Sec. 6654
1987            $14,493            $3,623             $783
                                  - 2 -


1988             50,029            12,507             3,198
1989              1,163               291               --
1990             34,767             8,692             2,290

After concessions by the parties, the only remaining issues are

whether petitioner is liable for the additions to tax set forth

below:

                                   Additions to Tax
       Year               Sec. 6651(a)          Sec. 6654
       1987                 $1,150                 $280
       1988                    611                  157
       1990                  1,186                  --

At the time the petition was filed, petitioner resided in

Philadelphia, Pennsylvania.     All section references are to the

Internal Revenue Code in effect for the years in issue, and all

Rule references are to the Tax Court Rules of Practice and

Procedure.

       Section 6651(a) imposes an addition to tax for failure to

file a tax return in a timely manner.       Petitioner's tax returns

for 1987, 1988, and 1990 were due on April 15, 1988, 1989, and

1991, respectively.    Petitioner, however, did not file such

returns until October 10, 1997.     Petitioner has failed to

establish that her tardiness was due to reasonable cause and not

due to willful neglect.     Sec. 6651(a); United States v. Boyle,

469 U.S. 241 (1985); Welch v. Helvering, 290 U.S. 111, 115

(1933).    Accordingly, petitioner is liable for the section

6651(a) additions to tax.
                                 - 3 -


     Section 6654 imposes an addition to tax for failure to make

estimated tax payments.   Petitioner did not remit estimated tax

payments for the years in issue.    In addition, she has failed to

establish that she falls within any of the exceptions to section

6654.   Therefore, petitioner is liable for the section 6654

additions to tax.

     All other arguments raised by the parties are either moot or

without merit.

     To reflect the foregoing,


                                              Decision will be entered

                                         pursuant to Rule 155.
