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cause is not defined in the Code, the regulations state: “If the
taxpayer exercised ordinary business care and prudence and was
nevertheless unable to file the return within the prescribed
time, then the delay is due to a reasonable cause.” Sec.
301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect has
been defined as a “conscious, intentional failure or reckless
indifference.” United States v. Boyle, 469 U.S. 241, 245 (1985).
In the instant case regarding Michoff, Jr., we have found
that he did have income sufficient to require the filing of a
return in both the 1986 and 1987 tax years. The unverified
belief of Michoff, Jr., that he had no taxes owing does not
constitute reasonable cause of the sort that will allow him to
escape the addition to tax under section 6651(a)(1). See Olsen
v. Commissioner, T.C. Memo. 1993-432. We sustain respondent on
this issue.
Failure To Pay Estimated Tax
Respondent determined an addition to tax for failure to pay
estimated tax for the 1986 and 1987 tax years for Michoff, Jr.
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Michoff, Jr., contends that he did not
have sufficient income in 1986 or 1987 to require him to pay
estimated taxes. Michoff, Jr., bears the burden of proving that
he is not liable for this penalty. Rule 142(a). Michoff, Jr.,
contends that he had a loss carryover from his business in 1985
and, thus, did not have sufficient income in 1986 or 1987 to
require him to pay estimated taxes. Michoff, Jr., offered no
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