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income from the sale of timber to C&D. In 1993, however,
petitioner received 47 gold coins in exchange for $17,811.45
worth of timber, and in 1994, petitioner received somewhere
between four and five gold coins in exchange for $1,635 worth of
timber. Accordingly, we hold that petitioner had unreported
income from the sale of timber for 1993 and 1994 of $17,811.45
and $1,635, respectively.
Issue 2. Additions to Tax--Section 6651(a)(1)
Respondent determined that pursuant to section 6651(a)(1)
petitioner was liable for late filing penalties of $1,018,
$1,054, and $1,092 for 1992, 1993, and 1994, respectively.
Petitioner did not address this issue.
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed (determined with regard to
any extension of time for filing), unless it is shown that such
failure is due to reasonable cause and not due to willful
neglect. Sec. 6651(a)(1); Webb v. Commissioner, T.C. Memo. 1993-
521, affd. without published opinion 46 F.3d 1149 (9th Cir.
1995). However, a taxpayer who is entitled to make a joint
return and whose gross income, when combined with the gross
income of his spouse, is, for the taxable year, less than the sum
of twice the exemption amount plus the applicable standard
deduction is generally exempt from filing a return. Sec.
6012(a)(1)(A)(iv). The filing exception under section 6012(a)
generally does not apply to any individual who has net earnings
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