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timely returns, unless the taxpayer can establish that such
failure "is due to reasonable cause and not due to willful
neglect". The addition to tax is 5 percent of the amount
required to be shown on the return for each month beyond the
return's due date, not to exceed 25 percent. See sec.
6651(a)(1).
Reasonable cause exists where a taxpayer exercises ordinary
business care and prudence and still is unable to file a timely
return. See Crocker v. Commissioner, 92 T.C. 899, 913 (1989);
Estate of Vriniotis v. Commissioner, 79 T.C. 298, 310 (1982);
sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect is
viewed as a conscious, intentional failure or reckless
indifference to the obligation to file. See United States v.
Boyle, 469 U.S. 241, 245-246 (1985); Estate of Newton v.
Commissioner, T.C. Memo. 1990-208. Whether petitioner has shown
reasonable cause and no willful neglect is a question of fact to
be decided on the entire record. See Estate of Duttenhofer v.
Commissioner, 49 T.C. 200, 204 (1967), affd. per curiam 410 F.2d
302 (6th Cir. 1969).
Section 6011(a) provides that any person made liable for any
tax imposed by Title 26 shall make a return or statement
according to the forms and regulations prescribed by the
Secretary. Section 6012(a) requires that every individual having
gross income that equals or exceeds the exemption amount must
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