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Willful neglect means a conscious, intentional failure or
reckless indifference. United States v. Boyle, supra at 245.
Petitioners have presented no persuasive evidence on this issue,
and the record does not otherwise establish that their failure to
file timely returns was due to reasonable cause and not due to
willful neglect. We sustain respondent’s determinations under
section 6651(a).
As to respondent’s determinations under section 6654,
section 6654(a) provides for an addition to tax "in the case of
any underpayment of estimated tax by an individual". Generally,
this addition to tax is mandatory, and there is no exception for
reasonable cause. Recklitis v. Commissioner, 91 T.C. 874, 913
(1988); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
However, no addition to tax is imposed if one of the exceptions
contained in section 6654 is met. Recklitis v. Commissioner,
supra at 913. Petitioners have offered no evidence to show that
any of the statutory exceptions apply. We sustain respondent’s
determinations under section 6654(a).
As to respondent’s determination under section 6662(a),
section 6662(a) and (b)(1) imposes a 20-percent accuracy-related
penalty on the portion of an underpayment that is due to
negligence or intentional disregard of rules or regulations.
Negligence includes a failure to attempt reasonably to comply
with the Code. See sec. 6662(c). Disregard includes a careless,
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