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returns and the taxes owed had to be submitted simultaneously.
Petitioner states that he “never had any willful intent not to
file” and that he “knew that * * * [he] was going to have to
file”.
A taxpayer’s inability to pay Federal income taxes does not
constitute reasonable cause for failure to file a timely return.
See Stokes v. Commissioner, T.C. Memo. 1989-661 (citing Fitch v.
Commissioner, T.C. Memo. 1975-36); see also Jones v.
Commissioner, 25 T.C. 1100, 1106 (1956), revd. on another issue
259 F.2d 300 (5th Cir. 1958); Sanders v. Commissioner, 21 T.C.
1012, 1019-1020 (1954). Since petitioner introduced no evidence
of any legitimate reason for his failure to file timely returns,
we hold that he did not have reasonable cause for his failure to
file as required by section 6651(a)(1) and that, therefore,
petitioner is liable for the additions to tax as revised by
respondent.
Section 6654 Addition to Tax
Section 6654(a) imposes an addition to tax in the case of
any underpayment of estimated tax by an individual. Sec.
6654(a). Unless a statutory exception applies, the addition to
tax under section 6654(a) is mandatory. See sec. 6654(a), (e);
Recklitis v. Commissioner, 91 T.C. 874, 913 (1988); Grosshandler
v. Commissioner, 75 T.C. 1, 20-21 (1980); see also Estate of
Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960) (“This section
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