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is presumed correct, and petitioner bears the burden of proving
that it is erroneous. Rule 142(a); Siebert v. Commissioner, T.C.
Memo. 1997-6. Petitioner has failed to produce any evidence on
the issue of his liability for self-employment taxes. Therefore,
we sustain respondent's determination that petitioner is liable
for self-employment taxes for 1989 and 1990.
The last issues to be addressed concern whether petitioner
is liable for the additions to tax under sections 6651(a)(1) and
6654(a) proposed by respondent. Section 6651(a)(1) provides an
addition to tax for failure to file a Federal income tax return
by its due date (determined with regard to extensions), unless
the taxpayer shows that such failure was due to reasonable cause
and not willful neglect. The taxpayer bears the burden of
proving both. United States v. Boyle, 469 U.S. 241, 245 (1985).
A showing of reasonable cause requires that the taxpayer
demonstrate that he exercised ordinary business care and prudence
but nevertheless was unable to file the return within the
prescribed time. Sec. 301.6651-1(c)(1), Proced. & Admin. Regs.;
see also United States v. Boyle, supra at 246.
Petitioner stipulated that he did not file individual income
tax returns for the years 1989 and 1990 but claims to have
reasonable cause because of the destruction of his records in the
truck accident previously discussed. However, the destruction of
his records in February 1992 does not constitute reasonable cause
for failing to file returns for 1989 and 1990, which were due on
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