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vague and conclusory and does not even address the specifics of
his duties in that year. We conclude that he has failed to
demonstrate error in respondent's determinations of liability for
self-employment tax in 1987 and 1989 and accordingly sustain
them.
Additions to Tax Under Section 6651(a)(1)
Respondent determined additions to tax for failure to timely
file returns under section 6651(a)(1) with respect to both years
in issue. Petitioner claims that his failure to file for these
years was due to reasonable cause.
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return unless it is shown that such failure is due
to reasonable cause and not due to willful neglect. The amount
of the addition to tax is determined on a graduated basis,
beginning at the rate of 5 percent of the amount required to be
shown on the return if the failure is not more than 1 month, with
an additional 5 percent for each additional month or fraction
thereof that such failure continues, not exceeding 25 percent in
the aggregate. Sec. 6651(a)(1).
To prove reasonable cause, a taxpayer must show that he
exercised ordinary business care and prudence but nevertheless
was unable to file the return when it was due. Crocker v.
Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-1(c)(1),
Proced. & Admin. Regs. Petitioner argues that he had reasonable
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