1382, 1383-1384 (9th Cir. 1986), affg. in part and remanding in
part T.C. Memo. 1984-197; Niedringhaus v. Commissioner, 99 T.C.
202, 212 (1992); Duralia v. Commissioner, T.C. Memo. 1994-269.
The Court finds that petitioner failed to file timely a
Federal income tax return for the year 1996.
In addition to the argument that he in fact timely filed his
return, petitioner makes several spurious arguments. He takes
the position that he should not be subject to the additions to
tax for not filing timely because: (1) He cannot get a fair
trial in the Tax Court because the Judges are paid from tax
revenues and are therefore biased; (2) there is waste and
mismanagement in the Internal Revenue Service and the Government
at large; (3) Mark Rich received a Presidential pardon; and (4)
American corporations pay presently a smaller share of the total
tax burden than in years past.
Section 6651(a)(1) imposes an addition to tax for failure to
file timely a Federal income tax return unless the taxpayer shows
that such failure was due to reasonable cause and not willful
neglect. See, United States v. Boyle, 469 U.S. 241, 245 (1985).
To prove "reasonable cause", a taxpayer must show that he
exercised ordinary business care and prudence and was
nevertheless unable to file the return within the prescribed
time. Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec.
301.6651-1(c)(1), Proced. & Admin. Regs.
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