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concede that he may have failed to timely file his tax returns,
petitioner stated at trial in Hadsell I:
Well, you know, for a long time the IRS sent me those
inquiring letters, and I’ve always had a philosophy;
ignore them and they’ll go away, but they didn’t. They
were persistent. So I made a mistake. I wrote to
them, and eventually the inquiring letters became
demanding, They wanted money. * * *
Additionally, when asked by the Court whether he filed a
1990 Federal or Oregon State income tax return or whether the
timing of his arrest interfered with the filing of such return,
petitioner replied: “And, you know, I can’t answer that”.
Upon the basis of the record, we find that petitioner has
not shown that he timely filed his Federal income tax returns for
the years at issue, and, therefore, hold that petitioner is
liable for additions to tax pursuant to section 6651(a)(1).
Respondent is sustained on this issue.
6. Additions to Tax for Failure To Pay Estimated Income Taxes
Section 6654(a) imposes an addition to tax where prepayments
of tax, either through withholding or estimated quarterly tax
payments during the year, do not equal the percentage of total
liability required under the statute. However, the addition to
tax is not imposed if the taxpayer can show that one of several
exceptions applies. See sec. 6654(e).
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