Thomas W. Boozer - Page 3

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Dallas, Texas, at the time this petition              
          was filed.                                                                  
               Petitioner earned a college degree with a major in banking.            
          He earned his living as a carpenter during the years in issue.              
          Petitioner failed to file U.S. Individual Income Tax Returns for            
          each of the years 1989 through 1995.  He asserts that he did not            
          believe he had to file tax returns until he was ordered by a                
          Court to do so.  The only source for this alleged belief was "a             
          little bit of studying * * * [with] a group of people who get               
          together in the form of a study group."                                     
                                       OPINION                                        
               Respondent determined that petitioner is liable for the                
          section 6651(a)(1) addition to tax for 1989, 1990, 1991, 1992,              
          and 1993.  Section 6651(a)(1) imposes an addition to tax for                
          failure to file a timely return, unless the taxpayer establishes            
          that the failure did not result from "willful neglect" and that             
          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,               








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