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Revenue in the amount of $129. Petitioner failed to file a 1992
Federal income tax return.
Petitioner testified that he worked for Aspen Office
Furniture and Denver Post where he earned "wages" not income
during the taxable year. Petitioner's contention that he had no
tax liability is based on various tax protester arguments.
Petitioner is a classic tax protester raising traditional
protester arguments. Such arguments are repeatedly rejected,
United States v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981), and
need not be addressed by this Court. Crain v. Commissioner, 737
F.2d 1417 (5th Cir. 1984); Rowlee v. Commissioner, 80 T.C. 1111
(1983); Nieman v. Commissioner, T.C. Memo. 1993-533.
The second issue is whether petitioner is liable for the
addition to tax pursuant to section 6651(a)(1). Petitioner bears
the burden of proving that respondent's determination is
incorrect. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes: (1) The
failure did not result from "willful neglect"; and (2) the
failure was "due to reasonable cause". "Willful neglect" has
been interpreted to mean a conscious, intentional failure, or
reckless indifference. United States v. Boyle, 469 U.S. 241,
245-246 (1985). "Reasonable cause" requires the taxpayer to
demonstrate that he exercised ordinary business care and prudence
and was nonetheless unable to file a return within the prescribed
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