Jonathan B. Geftman - Page 21

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          business care and prudence, and, nevertheless, was unable to file           
          the return within the prescribed time.  In re Stanford, supra at            
          1514; Fleming v. United States, supra at 1124; sec. 301.6651-               
          1(c)(1), Proced. & Admin. Regs.   Willful neglect means a                   
          conscious, intentional failure to file or reckless indifference.            
          United States v. Boyle, supra at 245.                                       
               Petitioner argues that his failure to file was due to                  
          reasonable cause because he was a minor during the year in issue            
          and was not responsible for his financial affairs.  We do not               
          find petitioner's argument persuasive.  His "youth and ignorance            
          at the time returns should have been filed" does not constitute             
          reasonable cause in the circumstances.  Bassett v. Commissioner,            
          67 F.3d 29, 30 (2d Cir. 1995), affg. 100 T.C. 650 (1993).                   
          Petitioner introduced no evidence that his failure to file was              
          due to reasonable cause and not due to willful neglect.                     
          Petitioner received Schedule K-1 from Trust C informing him that            
          his portion of Trust C's interest during 1984 was $47,113.  We              
          sustain respondent's determination under section 6651(a) for                
          petitioner's 1985 taxable year.                                             
          C.  Addition to Tax Under Section 6654                                      
               Respondent further determined an addition to tax under                 
          section 6654 for the year in issue, asserting that petitioner               
          failed to pay estimated tax.  This addition to tax is mandatory             
          unless petitioner proves that he comes within one of the                    
          exceptions provided in section 6654.  In re Stanford, supra at              




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