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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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