Peter Paul Lagasse - Page 4

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                  At trial, respondent presented a representative of the                                  
            Connecticut Department of Labor as well as an individual who was                              
            controller of Mark in 1993.  The witnesses presented records of                               
            their respective organizations that supported the amounts                                     
            determined in the notice of deficiency.  Petitioner did not                                   
            present any evidence to contradict the testimony and documents                                
            submitted by respondent supporting the determination.  Petitioner                             
            asserted that there was continuing corruption, and, therefore, he                             
            would not comply with the requirements of filing a return and                                 
            reporting income.  Petitioner has failed to establish that                                    
            respondent's determination is erroneous.  Since there is no                                   
            question that the unemployment compensation and the wages                                     
            constitute taxable income, respondent's determination as to the                               
            deficiency is sustained.                                                                      
                  Section 6651(a)(1) provides for an addition to tax for                                  
            failure to timely file a Federal income tax return.  Petitioner                               
            was required to file a 1993 Federal income tax return on or                                   
            before April 15, 1994.  Secs. 6012(a), 6072(a).  Section                                      
            6651(a)(1) further provides that a taxpayer may avoid the                                     
            addition to tax if the failure to file was due to reasonable                                  
            cause and not willful neglect.  United States v. Boyle, 469 U.S.                              
            241, 245 (1985).                                                                              
                  We conclude that petitioner's failure to file his 1993                                  
            return was due to willful neglect and not due to reasonable                                   
            cause.  Petitioner's unsupported assertions of illegal acts by                                




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