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failure to file was due to reasonable cause and not due to
willful neglect. See also United States v. Boyle, 469 U.S.
241, 245 (1985); Janpol v. Commissioner, supra at 504.
Reasonable cause is present where the taxpayer exercised
ordinary business care and prudence but was unable to file the
return within the prescribed time. United States v. Boyle,
supra at 245; sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
Willful neglect means a conscious, intentional failure or
reckless indifference. United States v. Boyle, supra at 245.
Whether a taxpayer acts with reasonable cause, and without
willful neglect, is decided on the basis of the entire record.
Estate of Duttenhofer v. Commissioner, 49 T.C. 200, 204 (1967),
affd. 410 F.2d 302 (6th Cir. 1969).
A disqualified person who engages in a prohibited
transaction is required to file an excise tax return for each
taxable year in the taxable period. Secs. 4975(f)(2), 6011;
sec. 54.6011-1(b), Pension Excise Tax Regs.; see also Janpol v.
Commissioner, supra at 500. Because petitioner was a
disqualified person who engaged in a prohibited transaction on
October 19, 1990, and the transaction remained uncorrected upon
issuance of the notice of deficiency, he was required to file
an excise tax return for 1990 and for each taxable year
thereafter up to and including 1996. See sec. 4975(f)(2)
(absent a prior correction or a prior assessment of excise tax
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