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aggregate unless such failure is due to reasonable cause and not
due to willful neglect.
Although petitioner assigned error to that determination,
petitioner has failed to propose any findings of fact with
respect thereto or advance any arguments in support of that
assignment. Petitioner is a calender-year taxpayer.
Petitioner’s 1987 return was filed on July 6, 1988, which is
prima facie untimely. See sec. 6072(a). Petitioner has failed
to prove that his untimely return was due to reasonable cause and
not due to willful neglect. Respondent’s determination of an
addition to tax under section 6651(a)(1) for 1987 is sustained.
B. Negligence
By her notice of deficiency, respondent determined additions
to tax against petitioner for negligence for all of the years in
issue. Section 6653(a) imposes one or more additions to tax
where an underpayment of tax is due to negligence or intentional
disregard of rules or regulations (hereafter, without
distinction, negligence). Section 6653(a)(1), for returns due in
1989, and section 6653(a)(1)(A), for returns due in 1987 and
1988, impose an addition to tax equal to 5 percent of the entire
underpayment if any portion of such underpayment is due to
negligence. Section 6653(a)(1)(B), for returns due in 1987 and
1988, imposes an addition to tax equal to 50 percent of the
interest payable under section 6601 with respect to the portion
of the underpayment due to negligence. "Negligence is lack of
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