Timie A. Morin - Page 4




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          reasoning and copious citation of precedent; to do so might                 
          suggest that these arguments have some colorable merit."  Crain             
          v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).                       
          Accordingly, we sustain respondent's deficiency determination.1             
               Respondent determined that petitioner is liable for                    
          additions to tax pursuant to section 6651(a)(1).  Section                   
          6651(a)(1) imposes an addition to tax for failure to file a                 
          return on the date prescribed (determined with regard to any                
          extension of time for filing), unless the taxpayer can establish            
          that such failure is due to reasonable cause and not due to                 
          willful neglect.  The taxpayer has the burden of proving the                
          addition is improper.  See Rule 142(a); United States v. Boyle,             
          469 U.S. 241, 245 (1985).  Petitioner stipulated that she did not           
          file returns for 1994 and 1995, and she offered no evidence                 
          showing that her failure to file was due to reasonable cause and            
          not due to willful neglect.  Accordingly, we hold that petitioner           
          is liable for the additions to tax under section 6651(a)(1).                
               Respondent also determined that petitioner is liable for               
          additions to tax pursuant to section 6654 for failing to make               
          estimated tax payments.  Petitioner did not offer any evidence at           


               1  Respondent also determined that petitioner is subject to            
          self-employment tax.  Petitioner presented no evidence at trial             
          regarding this issue and failed to address it on brief.                     
          Therefore, we hold that petitioner is subject to self-employment            
          tax.  See Rule 142(a); see also Petzoldt v. Commissioner, 92 T.C.           
          661, 683 (1989).                                                            




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