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ordinary care and prudence with respect to nontax matters, the
claimed mental illness or mental incapacity does not constitute
reasonable cause. See Carlson v. United States, supra at 923.
Except for his self-serving testimony, on which we are
unwilling to rely, petitioner has introduced no evidence estab-
lishing that he had a mental illness or mental incapacity which
prevented him from filing a return for each of the years at
issue. In fact, the record establishes that, throughout the
years at issue until the time of the trial in this case, peti-
tioner has worked as a sales manager and as a singer/composer and
has almost doubled his income throughout that period. On the
record before us, we find that petitioner has failed to carry his
burden of proving that he suffered from a mental illness or
mental incapacity which prevented him from filing a return for
each of the years at issue. On that record, we further find that
petitioner has failed to prove that he is not liable for the
addition to tax under section 6651(a)(1) for each of those years.
With respect to the determinations at issue under section
6654(a), on the record before us, we find that petitioner has
failed to show that any of the exceptions in section 6654(e)
apply in the instant case. On that record, we further find that
petitioner has failed to prove that he is not liable for the
addition to tax under section 6654(a) for each of the years at
issue.
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