Larry L. Bennett - Page 8

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          exemption for a dependent child.  Accordingly, we conclude that             
          petitioner is entitled to an additional exemption for each year             
          at issue.                                                                   
               Finally, respondent determined that petitioner is liable for           
          the addition to tax for failure to file a timely return under               
          section 6651(a)(1) and the addition to tax for failure to pay               
          estimated income tax under section 6654(a).  Petitioner has not             
          put forth any evidence to indicate that his failure to file tax             
          returns was due to reasonable cause and not due to willful                  
          neglect.  Sec. 6651(a); United States v. Boyle, 469 U.S. 241                
          (1985).  Further, petitioner has not shown that he satisfied any            
          of the exceptions under section 6654.  Accordingly, we sustain              
          respondent's determinations on these issues.                                
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          


















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