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in issue. Accordingly, petitioner is liable for Federal income
and self-employment taxes for each of the years in issue.
Petitioner received a $30,000 premature distribution from
his IRA. Section 72(t)(1) imposes a tax of 10 percent of the
amount of an early distribution from a qualified retirement
account. Section 72(t)(2) provides for certain exceptions to the
general rule contained in paragraph (1). Petitioner has not
argued that any of the statutory exceptions apply. Accordingly,
petitioner is liable for the 10-percent additional tax on the
$30,000 early distribution under section 72(t).
For 1989, petitioner filed an unsigned Form 1040.
Respondent determined that the form was not a valid return and
that petitioner was liable for a section 6651(a) addition to tax
for 1989. Section 6651(a)(1) imposes an addition to tax equal to
5 percent of the tax due for each month that a return is
delinquent, not to exceed 25 percent. The section 6651(a)(1)
addition to tax does not apply if the failure to timely file is
due to reasonable cause and not due to willful neglect.
Reasonable cause exists if the taxpayer exercised ordinary
business care and prudence and was nevertheless unable to file a
return within the prescribed time. Crocker v. Commissioner, 92
T.C. 899, 913 (1989); sec. 301.6651-1(c)(1), Proced. & Admin.
Regs. Respondent asserted the section 6651(a)(1) addition for
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