-39-
reasonable cause. See Rule 142(a); United States v. Boyle, 469
U.S. 241, 245 (1985).
The parties have stipulated that petitioner did not file an
income tax return for 1994. Respondent has determined that
petitioner did not have reasonable cause for his failure to file.
Having sustained respondent's determination that there was a
deficiency in petitioner's tax for 1994, we find that petitioner
was required to file a 1994 return and that he did not do so.
Petitioner did not argue or offer any evidence suggesting
that he had reasonable cause for his failure to file a 1994
return. Petitioner's arguments and evidence challenged only the
amount of the deficiency determined by respondent; petitioner did
not attempt to establish that he had cause for his failure to
file. Accordingly, we find that petitioner has not shown that
his failure to file a 1994 return was due to reasonable cause and
not to willful neglect. We therefore sustain respondent's
determination of the section 6651(a)(1) addition for 1994.
V. Estimated Tax Additions for 1989-94
Respondent also determined that petitioner is liable for
additions to tax under section 6654(a), for failure to pay
estimated tax in each of the years 1989-94. Section 6654(a)
provides for an addition to tax in the case of any underpayment
of estimated tax by an individual. The addition to tax under
section 6654 is mandatory absent a showing by the taxpayer that
one of the statutory exceptions applies. See Clayton v.
Commissioner, 102 T.C. at 653.
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