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245-246 (1985). "Reasonable cause" requires the taxpayer to
demonstrate that the taxpayer exercised ordinary business care
and prudence and was nevertheless unable to file a return within
the prescribed time. Id. at 246; sec. 301.6651-1(c)(1), Proced.
& Admin. Regs.
Petitioner has not shown that he exercised reasonable care
with regard to his failure to file returns. He has simply argued
that he believed he had no duty to file a tax return in the
absence of a court order. This alleged belief was based on
discussions petitioner had with other laypersons, not on any
advice received from tax professionals.
Assuming that petitioner is truthful about his belief, it
does not constitute reasonable cause under section 6651(a)(1).
It was not bolstered by advice from a competent tax professional
who had been informed of all the relevant facts. Yale Ave. Corp.
v. Commissioner, 58 T.C. 1062, 1076-1077 (1972); Stevens Bros.
Found., Inc. v. Commissioner, 39 T.C. 93, 133 (1962), affd. on
this issue, revd in part and remanded 324 F.2d 633, 646 (8th Cir.
1963); cf. United States v. Boyle, supra.
The preponderance of the evidence in the instant case shows
(1) that petitioner, a college graduate, intentionally failed to
file tax returns, based on an alleged belief that had no basis in
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