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evidence to carry the burden of proof regarding the increased
deficiency for 1993.
Additions to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
file a required return on or before the specified filing date.
The addition to tax is 5 percent of the amount required to be
shown as tax on the return and an additional 5 percent is imposed
for each additional month or fraction thereof during which the
failure continues, but not to exceed 25 percent in the aggregate.
See sec. 6651(a)(1). This addition to tax may be avoided only if
petitioner can show that his failure to file was due to
reasonable cause and not willful neglect. See Rule 142(a);
United States v. Boyle, 469 U.S. 241, 245-246 (1985).
The Form 1040 that petitioner submitted for 1993 was invalid
because it was not signed under penalties of perjury. See sec.
6065; Beard v. Commissioner, supra at 777; see also Richardson v.
Commissioner, supra at 824. Petitioner did not file or submit
any returns for 1994 or 1995. There is no evidence in the record
to support a finding that petitioner’s failure to file returns
for 1993, 1994, and 1995, was due to reasonable cause and not
willful neglect. We hold that the addition to tax under section
6651(a)(1) applies for the years in issue. We also hold that the
increased addition to tax in the amount of $1,458 applies for
1993 because, as previously stated, respondent has established
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