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On the instant record, we find that petitioner has failed to
satisfy his burden of proving that the Celebration stock became
worthless during 1989. Accordingly, we sustain respondent's
determination that petitioner is not entitled for that year to
treat that stock as worthless under section 165(g).
Section 6651(a)(1)
Respondent determined that petitioner is liable for each of
the years 1989 and 1990 for the addition to tax under section
6651(a)(1) for failing to file timely his return for each of
those years. Although petitioner presented no evidence at trial
with respect to those determinations, he contends on brief that,
because he believed that he overpaid his taxes for 1989 and 1990
and that he was owed a refund for those years, he did not have to
file returns for 1989 and 1990. In the 1989 and 1990 returns
that petitioner filed late, he reported gross income of $61,340
and $65,948, respectively, and claimed "Head of household" status
and two exemptions totaling $4,000 and $4,100, respectively.
There is no determination in the notice that petitioner is not
entitled to the head of household status and the two exemptions
that he claimed in those returns.
Section 6012(a)(1)(A) generally requires that every indi-
vidual whose gross income for the taxable year equals or exceeds
the "exemption amount" must file a return. The term "exemption
amount" has the same meaning as provided in section 151(d). Sec.
6012(a)(1)(D)(ii). Certain exceptions apply to the general re-
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