Anthony Tinsman - Page 18





                                        - 18 -                                        
               There is no evidence in the record that suggests that                  
          petitioner's failure to file timely a Federal income tax return             
          for any year in issue was due to reasonable cause and not due to            
          willful neglect.  Consequently, we sustain respondent's                     
          determination that petitioner is liable for the additions to tax            
          under section 6651(a)(1) for the years 1994 through 1996.                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               
































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