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Fifth, petitioner argues that he is not liable for the
addition to tax for failure to file a timely return as
provided by section 6651(a)(1) because his failure to file
each of the subject tax returns was due to reasonable
cause. He claims that he did not file those tax returns
because he was uncertain about whether he could claim his
oldest daughter as a dependent and he wanted to "call
attention" to himself. At trial, petitioner stated as
follows:
Q Is there any reason that you did not file
your returns, other than your uncertainty
about the -- whether your oldest daughter
Angie, was a dependent or not? Is that the
only reason?
A No. The other reason was to call attention
on myself.
Q You thought that would get you noticed by
the IRS?
A I thought it would lead to answers.
Section 6651(a)(1) provides that if a taxpayer fails
to file a tax return on the date prescribed for filing,
including any extension of time for filing, an addition to
tax in an amount equal to 5 percent of the tax required to
be shown on the return will be imposed for each month, or
fraction thereof, during which the failure to file
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