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the reasons stated above for our rejection of petitioner's con-
stitutional claim, we find that petitioner has not established
that respondent abused her discretion by not complying with her
duty to enforce the tax law consistently with respect to him,
Radcliffe, and BOT.
VII. Additions to Tax
Neither Radcliffe nor BOT filed withholding tax returns for
the years at issue. Nor did either of those corporations make a
deposit of withholding tax with respect to those years.
Respondent determined that Radcliffe and BOT are liable for
(1) the additions to tax imposed by section 6651(a)(1) for fail-
ure to file timely withholding tax returns, (2) the additions to
tax imposed by section 6653(a) for negligence or disregard of
rules or regulations, and (3) the penalties imposed by section
6656(a) for failure to make timely deposits of taxes. Respondent
further determined that petitioner is liable as a transferee of
those corporations for those additions to tax and penalties.
Section 6651(a)(1) imposes an addition to tax for failure to
file timely a tax return. If the failure continues for more than
four months, the addition to tax is equal to 25 percent of the
amount of tax required to be shown in the return. The addition
to tax prescribed by section 6651(a)(1) does not apply if the
failure is due to reasonable cause, and not to willful neglect.
Sec. 6651(a)(1). In order to establish reasonable cause, a
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