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claimed expenses, petitioner is simply not entitled to deduct
them.
However, petitioner has also claimed a deduction for $726 in
pager expenses. After having examined the checks, we are
convinced that such amount was in fact spent on pager services,
and that under the circumstances of this case, this expense was
more likely than not a business expense. We therefore conclude
petitioner is entitled to deduct it.
We hold that other than this amount (and the deductions
conceded by respondent), petitioner is not entitled to any of the
additional deductions claimed.
V. Additions to Tax
Section 6651(a)(1) imposes an addition to tax for the
failure to file an income tax return within the time prescribed
by law, unless it is shown that the failure is due to reasonable
cause and not to willful neglect. The taxpayer bears the burden
of showing that reasonable cause exists. See Rule 142(a); United
States v. Boyle, 469 U.S. 241, 245 (1985).
Petitioner did not file a return for 1993, and there is no
evidence he had reasonable cause for this failure. Accordingly,
petitioner is liable for the maximum 25-percent addition for
failure to file, applied to the amount of the deficiency as
redetermined in accordance with this opinion.
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