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(1985); United States v. Nordbrock, 38 F.3d 440 (9th Cir. 1994).
A failure to file a timely Federal income tax return is due to
reasonable cause if the taxpayer exercised ordinary business care
and prudence and, nevertheless, was unable to file the return
within the prescribed time. See sec. 301.6651-1(c)(1), Proced. &
Admin. Regs. Willful neglect means a conscious, intentional
failure to file or reckless indifference. See United States v.
Boyle, supra at 245.
Petitioner has offered no evidence to show that his failure
to file was due to reasonable cause and not willful neglect. The
evidence is clear that petitioner’s actions were deliberate,
intentional, and in complete disregard of the statutes and
respondent’s regulations. Petitioner made no attempt to file an
authentic tax return for any of the years at issue.
Petitioner offers the “excuse” that his nonfiling was as an
act of “non-violent civil disobedience” on a “human rights
issue”. As we stated in Klunder v. Commissioner, T.C. Memo.
1991-489: “Petitioner wants the best of both worlds, to civilly
disobey and also to be absolved of the additions to tax.”
Whether or not petitioner considers his nonfiling an act of civil
disobedience, he must accept the consequences of actions
knowingly taken. See Kahn v. United States, 753 F.2d 1208, 1215-
1216 (3d Cir. 1985); United States v. Malinowski, 472 F.2d 850,
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