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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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