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reliance on an agent, and such reliance is not ‘reasonable cause’
for a late filing under � 6651(a)(1).” Id. at 251-252; see also
Cooper v. Commissioner, T.C. Memo. 1997-494; Radabaugh v.
Commissioner, T.C. Memo. 1992-572.
Given this standard, the failure on the part of petitioner
here to ensure that his return was mailed with sufficient postage
prepaid and postmarked by the October 15, 1996, due date renders
him subject to the section 6651(a) addition to tax. Even if the
return was stamped and mailed by the accountant, as petitioner
claims, such reliance upon an agent for timely filing would not
constitute reasonable cause within the meaning of the statute.
Furthermore, nothing in the record supports petitioner’s related
contention that Postal Service error is responsible for the
untimeliness. Although petitioner asserts that 64 cents was in
fact sufficient postage, he did not offer into evidence the
actual weight of the original return and envelope. The envelope
in which the return was successfully sent bears 78 cents postage
affixed by a postal meter. Petitioner has not shown that the
return, when weighed by the meter, was not heavy enough to
require 78 cents.
Section 6662(a) Accuracy-Related Penalty
Subsection (a) of section 6662 imposes an accuracy-related
penalty in the amount of 20 percent of any underpayment that is
attributable to causes specified in subsection (b). Subsection
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