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jurisdiction to decide this case; and (3) an income tax violates
the Sixteenth Amendment because it is an impermissible "direct
tax". We see no need to fully describe each of petitioner's
constitutional arguments or to address them individually. To do
so might imply that the arguments have some colorable merit when
in fact they are groundless.
It is sufficient to note that petitioner readily
acknowledges that he received income yet refuses to pay tax on
it. Accordingly, we hold that petitioner is liable for the
deficiencies determined by respondent.
Respondent determined additions to tax under sections
6651(a)(1) and 6654. Section 6651(a)(1) imposes an addition to
tax for failure to file a timely return unless it is shown that
such failure to file was due to reasonable cause and not due to
willful neglect. Petitioner bears the burden of proving that he
had reasonable cause for failing to file tax returns for the
years in issue. Rule 142(a); Larsen v. Commissioner, 765 F.2d
939, 941 (9th Cir. 1985). Petitioner's tax protester rhetoric
does not establish reasonable cause. Accordingly, we hold that
petitioner is liable for additions to tax under section
6651(a)(1).
Section 6654(a) generally imposes an addition to tax if the
total tax withheld and any estimated tax payments made during a
year do not equal or exceed the threshold set forth in section
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