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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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