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continues, up to a maximum of 25 percent. The addition to
tax is mandatory unless a taxpayer's failure to file a tax
return is due to reasonable cause and is not due to willful
neglect. Sec. 6651(a)(1). See generally Estate of
Cavenaugh v. Commissioner, 100 T.C. 407, 426 (1993), affd.
in part and revd. in part on other grounds 51 F.3d 597
(5th Cir. 1995). In order to establish reasonable cause,
a taxpayer must show that he or she was unable to file a
tax return despite the exercise of ordinary business care
and prudence. See generally Bassett v. Commissioner, 67
F.3d 29, 31 (2d Cir. 1995), affg. 100 T.C. 650 (1993);
sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
As mentioned above, petitioner claims that his failure
to file each of the subject returns was due to reasonable
cause on the grounds that he did not know whether to report
his oldest daughter as a dependent and he wanted to "call
attention" to himself. Petitioner's testimony hardly shows
that he was prevented from filing any of the subject
returns despite the exercise of ordinary business care and
prudence. To the contrary, petitioner's testimony suggests
that he chose not to file his returns in an attempt to
"call attention" to himself. Thus, it appears that his
failure to file was not the result of the exercise of
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