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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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Last modified: May 25, 2011