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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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