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United States v. Boyle, supra at 246; sec. 301.6651-1(c)(1),
Proced. & Admin. Regs. Willful neglect means a conscious,
intentional failure to file or reckless indifference. United
States v. Boyle, supra at 245.
Petitioner was required to file Federal income tax returns for
1989-94. Sec. 6012. He failed to do so and offered no satisfactory
explanation. Nor has he presented any evidence to prove that his
failure to file was due to reasonable cause and not willful
neglect. In fact, petitioner wrote several letters to the IRS
asserting that he was not a taxpayer and accordingly refused to
file income tax returns.7 Thus, we sustain respondent's
determination of the section 6651(a)(1) additions to tax for the
years in issue (1989-94).
Respondent also determined an addition to tax pursuant to
section 6654(a) for the years in issue, on the basis of
petitioner's failure to pay estimated tax. Where payments of tax,
either through withholding or by making estimated quarterly tax
payments during the course of the year, do not equal the percentage
of total liability required under the statute, imposition of the
section 6654(a) addition to tax is mandatory, unless the taxpayer
shows that one of several statutory exceptions applies. Sec.
6654(a); Niedringhaus v. Commissioner, supra at 222; Recklitis v.
7 At trial, petitioner testified that he wrote the
letters on the basis of "bad" advice he received.
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