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not more than 1 month, with an additional 5 percent for
each additional month or fraction thereof during which
such failure continues, not exceeding 25 percent in the
aggregate. Sec. 6651(a)(1).
To escape the addition to tax for filing late returns,
petitioner has the burden of proving (1) that the failure to file
did not result from wilful neglect, and (2) that the failure was
due to reasonable cause. See United States v. Boyle, 469 U.S.
241, 245 (1985). Reasonable cause requires taxpayers to
demonstrate that they exercised "ordinary business care and
prudence" but nevertheless were "unable to file the return within
the prescribed time." Sec. 301.6651-1(c)(1), Proced. and Admin.
Regs.
For all relevant years, petitioner failed to file returns.
The record in this case is void of any evidence of the reason for
this failure. Thus, the record is void of evidence that the
failure was for reasonable cause. We sustain respondent's
determination of additions to tax under section 6651(a)(1) for
all years.
Respondent determined additions to tax for negligence for
1982 through 1988. Respondent determined petitioner's
underpayment of income tax in each year was due to negligence or
intentional disregard of rules or regulations. For 1982 through
1985, section 6653(a)(1) imposes an addition to tax equal to 5
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