Chrys L. Udoh - Page 12




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          intentional failure or reckless indifference to the obligation to           
          file.  See United States v. Boyle, supra.                                   
               Petitioner filed his 1994 tax return on May 3, 1996.                   
          Petitioner has not provided any explanation for the late filing             
          of the return.  Petitioner has not addressed the issue in his               
          pleadings or his testimony.  Petitioner has not established his             
          late filing of his 1994 Federal income tax return was due to                
          reasonable cause and not willful neglect.  Accordingly, we hold             
          petitioner is liable for the addition to tax under section                  
          6651(a).                                                                    
               We have considered all of petitioner's arguments and, to the           
          extent not discussed above, find them to be without merit.4                 
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          










               4    Petitioner asserts that respondent has wrongfully                 
          assessed and levied Federal and District of Columbia tax refunds            
          granted for the 1997 tax year, while he is a petitioner before              
          this Court.  The record before us demonstrates the levy was                 
          applied to petitioner's assessed tax liabilities for tax year               
          1993, a year not before us.                                                 




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