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due to reasonable cause and not willful neglect. See Rule
142(a); United States v. Boyle, 469 U.S. 241, 245-246 (1985).
The Forms 1040 that petitioner submitted for the years in
issue were unsigned, undated, and stamped received by
respondent’s Ogden Service Center on October 21, 1997, long after
the due dates for filing returns for the years in issue. The
only information petitioner provided on the Forms 1040 was his
name, a mailing address, and his Social Security number. Where
other information was required, petitioner simply wrote “not
required”. To each Form 1040, petitioner attached a Form W-2, as
provided by United Airlines. Petitioner also attached to each
Form 1040 a typed explanation as to why he “intentionally omitted
non-required information from [his] [F]orm 1040.”
Respondent also determined that petitioner is liable for
additions to tax pursuant to section 6654. Section 6654 provides
an addition to tax for failure to pay estimated taxes. Unless
petitioner demonstrates that one of the statutory exceptions
applies, imposition of this addition to tax is mandatory where
prepayments of tax, either through withholding or by making
estimated quarterly tax payments during the course of the taxable
year, do not equal the percentage of total liability required
under the statute. See sec. 6654(a); Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). Petitioner bears the
burden of proving his entitlement to any exception. See
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