Robert D. Mueller - Page 10

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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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