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fraction thereof during which the failure to file continues, up
to a maximum of 25 percent. See sec. 6651(a)(1).
The parties have stipulated that respondent received the
returns for each of the years in issue on December 16, 1996.
This was more than 5 months after the due dates, including any
extensions available to petitioner pursuant to section 6081(a),
for the returns for taxable years 1992, 1993, and 1994. With
respect to the 1995 taxable year, respondent has no record
indicating that petitioner was granted an extension of time to
file for that year, and petitioner has offered no evidence with
respect to any extension. Accordingly, we conclude that the 1995
return was filed more than 5 months after its due date.
Petitioner has offered no evidence of reasonable cause.
Therefore, petitioner is liable for section 6651(a)(1) additions
to tax equal to 25 percent of the amount of the tax required to
be shown on the return for each of the years in issue.
3. Accuracy-Related Penalties Under Section 6662
Petitioner bears the burden of proving that the
determinations pursuant to section 6662(a) are erroneous. See
Rule 142(a). Petitioner has introduced no evidence relating to
these determinations. Therefore, he is liable for accuracy-
related penalties under section 6662(a).
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