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were self-employment income during the taxable years in which
such payments were received. He has also stipulated that
respondent properly determined the amounts of his distributive
shares of FSC's income, loss, and deductions for the taxable
years in issue.
The first issue for decision is whether petitioner received
and failed to report income during the taxable years in issue.
Petitioner has stipulated to all of the adjustments in the
statutory notice of deficiency except for the unreported interest
income determined from information returns received by
respondent. Petitioner has not asserted any reasonable dispute
with respect to the accuracy of the information returns. Cf.
sec. 6201(d). Based on the record, we find that petitioner has
failed to prove any error in respondent's determinations of his
unreported income. Rule 142(a). Accordingly, we hold that
petitioner received and failed to report income during the
taxable years in issue in the amounts determined by respondent.
The second issue for decision is whether petitioner is
liable for the section 6651(a)(1) additions to tax for failure to
file his returns for the taxable years in issue.
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes that such
failure is due to reasonable cause and not due to willful
neglect. "Reasonable cause" requires the taxpayer to demonstrate
that he exercised ordinary business care and prudence and was
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Last modified: May 25, 2011