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hospital insurance benefits to self-employed persons. The
obligation to pay self-employment tax is mandatory if the
requirements of section 1401 are met as they are in this case.
We hold, therefore, that petitioner is liable for self-employment
tax as modified by respondent.
Additions to Tax Under Section 6651(a)(1)
Section 6651(a)(1) authorizes the imposition of an addition
to tax for failure to file a timely return, unless it is shown
that such failure is due to reasonable cause and not due to
willful neglect. See sec. 6651(a)(1); United States v. Boyle,
469 U.S. 241, 245 (1985); United States v. Nordbrock, 38 F.3d
440, 444 (9th Cir. 1994); Harris v. Commissioner, T.C. Memo.
1998-332. A failure to file a timely Federal income tax return
is due to reasonable cause if the taxpayer exercised ordinary
business care and prudence and, nevertheless, was unable to file
the return within the prescribed time. See sec.
301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect means a
conscious, intentional failure to file or reckless indifference
toward filing. See United States v. Boyle, supra.
Petitioner concedes he did not file Federal income tax
returns or applications for extensions of time to file for 1990
through 1997. Petitioner contends that he did not file returns
because he did not have money to pay the taxes he owed at the
time the returns were due, and it was his understanding that the
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