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3. Whether petitioner, pursuant to section 6653(a), is
liable for an addition to tax for negligence relating to his 1979
tax year. We hold that he is liable.
FINDINGS OF FACT
Petitioner resided in Gerona, Spain, at the time his
petition was filed. During the years in issue, he was employed
by Measurex Corp. (Measurex), a California corporation, and by
Saab-Totem, Inc. (Saab-Totem), a Washington corporation.
In 1980, petitioner received a $5,845 vacation allowance
from Measurex and realized a $328,455.37 long-term capital gain
attributable to the sale of 12,500 shares of Measurex stock.
During that year, he also submitted to Measurex and Saab-Totem
Forms W-4E. On these forms petitioner stated, under penalties of
perjury, that he incurred no income tax liability for 1979 and
that he anticipated no income tax liability for 1980.
Petitioner submitted to respondent two tax forms relating to
1979 and three tax forms relating to 1980. On April 18, 1980,
and April 17, 1981, respondent received Forms 1040 relating,
respectively, to petitioner's 1979 and 1980 tax years.
Petitioner, on these forms, provided objections, based on the
Fifth Amendment privilege against self-incrimination, to the tax
return filing requirement. After receiving these forms, the
Internal Revenue Service (IRS) began investigating petitioner's
1979 and 1980 tax liability. On August 13, 1981, petitioner
wrote a letter to Don Waite, an employee of Measurex, suggesting
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