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within the prescribed time. Sec. 301.6651-1(c)(1), Proced. &
Admin. Regs. Willful neglect means a conscious, intentional
failure or reckless indifference. United States v. Boyle, 469
U.S. 241, 245 (1985). Petitioner admittedly filed no returns
for 1993 and 1994 although the amount of income he received
required him to do so. See sec. 6012. We find that petitioner's
failure to file was not due to reasonable cause. We sustain
respondent's determination on this issue.
III. Section 6654 -- Failure To Pay Estimated Income Tax
Respondent determined that petitioner underpaid his
estimated income tax and is liable for additions to tax under
section 6654. Where payments of tax, either through withholding
or by making estimated tax payments, do not equal the percentage
of the total liability required under the statute, imposition of
the addition to tax under section 6654 is automatic, absent a
showing that the taxpayer has met one of the exceptions contained
therein. See Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Tillman v. Commissioner, T.C. Memo. 1996-8. Because petitioner
has not shown that any one of the exceptions applies, we sustain
respondent's determination on this issue.
IV. Section 6673--Penalty Awarded by Court
We decide sua sponte to impose a penalty upon petitioner
under section 6673(a). Section 6673(a)(1) authorizes the Court
to require a taxpayer to pay to the United States a penalty not
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