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Respondent determined that petitioner's income for each of
the years in issue is subject to self-employment tax under
section 1401, and petitioner has not disputed this determination.
We hold for respondent on this issue.
Respondent also determined that petitioner is liable for
additions to tax for the years in issue under sections 6651(a)
and 6654(a).
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes: (1) The
failure did not result from "willful neglect"; and (2) the
failure was "due to reasonable cause". "Willful neglect" has
been interpreted to mean a conscious, intentional failure, or
reckless indifference. United States v. Boyle, 469 U.S. 241,
245-246 (1985). "Reasonable cause" requires the taxpayer to
demonstrate that he exercised ordinary business care and prudence
and was nonetheless unable to file a return within the prescribed
time. Id. at 246; sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
The addition to tax equals 5 percent of the tax required to be
shown on the return for the first month, with an additional 5
percent for each additional month or fraction of a month during
which the failure to file continues, not to exceed a maximum of
25 percent. Sec. 6651(a)(1).
Petitioner did not testify as to his failure to file Federal
income tax returns for the years in issue. Based on the record
we find petitioner intentionally failed to file his Federal
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