- 11 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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