§7741

not file returns for 1986, 1987, 1988, and 1989, or any years thereafter. 5(...continued) . establishes is not attributable to fraud. 6See Omnibus Budget Reconciliation Act of 1989, Pub. L. 101- 239, sec. 7721(c)(1) (deleting Code sec. 6653(b)), and sec. 7741(a) (inserting the new Code sec. 6651(f)). SEC. 6651(a). Addition to the Tax.--In case of failúre-- (1) to file any return required under authority of subchapter A of chapter 61 * * * there shall be' added to the amount required to be shown

lent failure to file an income tax return for the year 1993 and in her motion requests that the Court find that there is due from petitioner an addition to tax under section 6651(f).2 Rule 34(b)(5) relieves petitioner from reciting facts underlying 2Sec. 7741(a) of the Omnibus Budget Reconciliation Act of 1989 (OBRA), Pub. L. 101-239, 103 Stat. 2106, 2404-2405, added subsec. (f) to sec. 6651 effective in cases of failure to file returns the due date for which (determined without regard to extens