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conscious, intentional failure to file or reckless indifference.
United States v. Boyle, supra at 245.
Petitioner has offered no evidence to show that his failure
to file was due to reasonable cause and not willful neglect.
Accordingly, we sustain respondent's determination under section
6651(a)(1) for petitioner's 1990 and 1991 taxable years.
3. Addition to Tax Under Section 6654(a)
Respondent further determined an addition to tax under
section 6654(a) for each of the years in issue, asserting that
petitioner failed to pay estimated tax. This addition to tax is
mandatory unless petitioner proves that he met one of the
exceptions contained in section 6654. Recklitis v. Commissioner,
91 T.C. 874, 913 (1988). Petitioner has offered no evidence to
show that any of the statutory exceptions apply. Accordingly, we
sustain respondent's determination under section 6654(a) for
petitioner's 1990 and 1991 taxable years.
We have considered all arguments made by petitioner for
contrary holdings and, to the extent not discussed above, find
them to be without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011