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care and prudence and was, nevertheless, unable to file his
return within the date prescribed by law. Crocker v.
Commissioner, 92 T.C. 899, 913 (1989); Estate of Vriniotis v.
Commissioner, 79 T.C. 298, 310 (1982); sec. 301.6651-1(c)(1),
Proced. & Admin. Regs. Willful neglect is viewed as a conscious,
intentional failure or reckless indifference to the obligation to
file. United States v. Boyle, supra.
Petitioner never filed a return for 1993. Petitioner filed
his 1995 return on June 29, 1998, and his 1996 return on August
3, 1998. Petitioner vaguely alluded to an illness in his
petition as a reason for his failure to timely file. Otherwise,
petitioner has not provided any explanation for the late filings
of the returns. Petitioner has not established his late filings
of his 1993, 1995, and 1996 Federal income tax returns were due
to reasonable cause and not willful neglect. Accordingly, we
hold petitioner is liable for the additions to tax under section
6651(a).
6. Section 6654(a) Addition to Tax
Section 6654(a) imposes an addition to tax in the case of
any underpayment of estimated tax by an individual. This Court
has jurisdiction to review respondent’s determination of this
addition to tax only if the taxpayer does not file a return for
the taxable year. Sec. 6665(b)(2); Meyer v. Commissioner, 97
T.C. 555, 562 (1991). Petitioner failed to file a return for the
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