- 12 -
737 F.2d 1417, 1417 (5th Cir. 1984), where the Court of Appeals
for the Fifth Circuit stated, "We perceive no need to refute
these arguments with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit."
Respondent's determinations of the deficiencies in these
cases are sustained.
2. Section 6651(a) Failure to File
Respondent determined that petitioner is liable for
additions to tax under section 6651(a) for each of the taxable
years at issue. Section 6651(a)(1) imposes an addition to tax
for a taxpayer's failure to file a required return on or before
the specified filing date, including extensions. The addition to
tax may be avoided, however, if the taxpayer can show that the
failure to file the return was due to reasonable cause and not
due to willful neglect. Sec. 6651(a)(1); Richardson v.
Commissioner, 72 T.C. 818, 826-827 (1979). The burden of proof
is on petitioner. Rule 142(a).
Petitioner did not file a Form 1040, U.S. Individual Income
Tax Return, a Form 1040A, U.S. Individual Income Tax Return, or a
Form 1040EZ, Income Tax Return for Single Filers with No
Dependents, for any of the taxable years at issue. Petitioner
did not offer any evidence or testimony to the contrary, but
argued instead that the Forms W-2 filed by her employers with the
Internal Revenue Service satisfied her filing obligations. As
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