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neglect. Sec. 6651(a); Rule 142(a); United States v. Boyle,
469 U.S. 241, 245 (1985); In re Stanford, 979 F.2d 1511, 1512
(11th Cir. 1992). A failure to file a Federal income tax return
is due to reasonable cause if the taxpayer exercised ordinary
business care and prudence and, nevertheless, was unable to file
the return within the prescribed time. In re Stanford, supra at
1514; sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful
neglect means a conscious, intentional failure or reckless
indifference. United States v. Boyle, supra at 245.
As we understand petitioner’s argument, he did not file
income tax returns due to an absence of forms pertaining to his
situation. Petitioner testified that he did not want to swear
under oath that his return was correct because he would be
committing perjury by stating that he was an independent
contractor. We find this argument unpersuasive. Because
petitioner has failed to prove that his failure to file was due
to reasonable cause and not due to willful neglect, we sustain
respondent on this issue.
4. Additions to Tax Under Section 6654
Respondent determined an addition to tax under section 6654
for each year in issue asserting that petitioner failed to pay
estimated tax. This addition to tax is mandatory unless
petitioner proves that he has met one of the exceptions contained
in section 6654. In re Stanford, supra at 1514; Recklitis v.
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