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(5th Cir. 1995). Accordingly, we sustain respondent's
disallowance of the deductions for the legal expenses and the
"claim of right" expenses.
The itemized deductions substantiated by petitioner or
allowed by the Court are less than the standard deduction for an
unmarried individual. Sec. 63(c)(2)(C). Consequently,
petitioner is entitled to the standard deduction for his 1994 tax
year.
Respondent contends that petitioner is liable for an
addition to tax pursuant to section 6651(a)(1). Section
6651(a)(1) imposes an addition to tax for failure to file a
Federal income tax return by its due date, determined with regard
to any extension of time for filing previously granted. The
addition equals 5 percent for each month that the return is late,
not to exceed 25 percent. Sec. 6651(a)(1). Additions to tax
under sections 6651(a)(1) are imposed unless the taxpayer
establishes that the failure was due to reasonable cause and not
willful neglect. Sec. 6651(a)(1). The taxpayer must prove both
reasonable cause and a lack of willful neglect. Crocker v.
Commissioner, 92 T.C. 899, 912 (1989). "Reasonable cause"
requires the taxpayer to demonstrate that he exercised ordinary
business care and prudence. United States v. Boyle, 469 U.S.
241, 246 (1985). Willful neglect is defined as a "conscious,
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