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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 filed his 1994 tax return on October 18, 1996.
Petitioner has not provided any explanation for the late filing
of the return. Petitioner did not address the issue in his
pleadings or his testimony. Petitioner has not established his
late filing of his 1994 Federal income tax return was due to
reasonable cause and not willful neglect. Accordingly, we hold
petitioner is liable for the addition to tax under section
6651(a).
E. Accuracy-Related Penalty
Respondent determined petitioner is liable for the accuracy-
related penalty under section 6662(a) for 1996. The accuracy-
related penalty is equal to 20 percent of any portion of an
underpayment of tax required to be shown on the return that is
attributable to the taxpayer’s negligence or disregard of rules
or regulations. Sec. 6662(a) and (b)(1). “Negligence” consists
of any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code and also includes any
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