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Petitioner testified that he could have secured all of the
necessary information to prepare and timely file his 1987 and
1988 returns from other sources. Petitioner has failed to prove
that his untimely filing was due to reasonable cause and not due
to willful neglect. Accordingly, we sustain respondent's
determination that petitioner is liable for the addition to tax
under section 6651(a)(1) for 1987 and 1988.
We have considered all arguments made by petitioner and, to
the extent not addressed above, find them to be without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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