Solomon Mayer - Page 9




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            imposes an addition to tax for failure to pay estimated income                             
            taxes.                                                                                     
                  For 1994 only, petitioner offers the excuse that the seizure                         
            of his business records in 1995 and the return of only some of                             
            those records by the attorney general of New York constitutes                              
            reasonable cause for petitioner’s failure to file his 1994                                 
            Federal income tax return.  We disagree.  Petitioner had a                                 
            pattern of not filing his income tax returns.  We regard                                   
            petitioner’s argument that he would have filed for 1994 but for                            
            the seizure of his records as not credible.                                                
                  We sustain respondent’s determination of all of the                                  
            additions to tax.                                                                          
                  To reflect the foregoing,                                                            
                                                      Decision will be entered                         
                                                under Rule 155.                                        






















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