Rosa Janus - Page 12

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          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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