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that provides any basis from which we could determine the amount
of the 1984 NOL that was absorbed in the years before 1986, the
earliest year before the Court. Accordingly, petitioner has not
shown that he is entitled to deductions under section 172 for any
of the years before the Court.
Additions to Tax and Penalties
Respondent determined additions to tax for failure to timely
file returns under section 6651(a) for all the years at issue;
additions to tax for negligence under section 6653(a)(1)(A) and
(B) for 1986 and 1987; an addition to tax for negligence under
section 6653(a)(1) for 1988; additions to tax for substantial
understatements under section 6661(a) for 1986, 1987, and 1988;
and accuracy-related penalties for negligence under section
6662(a) for 1989 and 1990.
Section 6651(a) imposes an addition to tax for failure to
timely file returns "unless it is shown that such failure is due
to reasonable cause and not due to willful neglect". Sec.
6651(a)(1). Reasonable cause "calls on the taxpayer to
demonstrate that he exercised 'ordinary business care and
prudence' but nevertheless was 'unable to file the return within
the prescribed time.'" United States v. Boyle, 469 U.S. 241, 246
(1985) (quoting 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.
It is undisputed that the returns for the taxable years 1986
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