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or incurred during the taxable year. Although the bank
statements may be taken as substantiation that bank charges were
paid, petitioner did not offer any evidence that any part of the
bank charges was ordinary and necessary business expenses.
Petitioner's bank accounts appear to be personal in nature, and
there is no indication that the accounts were used in a trade or
business. We find that petitioner has not met his burden of
proving that bank charges are proper deductions.
Respondent also determined additions to tax under section
6651(a)(1) for petitioner's failure to file his 1987 through 1992
returns. Section 6651(a)(1) imposes an addition to tax of 5
percent of the amount of the tax due for each month a return is
delinquent, up to a maximum of 25 percent. The addition to tax
is not applicable if it is shown that such failure is due to
reasonable cause and not willful neglect. Sec. 6651(a)(1);
United States v. Boyle, 469 U.S. 241, 245 (1985). Petitioner has
the burden of proving that his failure to file was due to
reasonable cause and not willful neglect. Niedringhaus v.
Commissioner, 99 T.C. 202, 220-221 (1992).
Petitioner has failed to show that his failure to file
returns for the taxable 1987 through 1992 was due to reasonable
cause and not willful neglect. Petitioner is liable for the
additions to tax under section 6651(a)(1) for the taxable years
1987 through 1992.
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