- 17 -
ity that he owed for those years.
In support of his position under section 6651(a)(1) and (2),
petitioner attempts to distinguish Ferguson v. Commissioner, T.C.
Memo. 1994-114, and Knight v. Commissioner, T.C. Memo. 1984-376,
from the instant case. We find the facts in those cases relating
to the addition to tax under section 6651(a)(1) to be similar to
the facts in the case before us. In Ferguson, the taxpayer
contended that he failed to file timely his returns for the three
years involved in that case “because he was busy working two
jobs, because he believed the amount of his withholdings exceeded
the amount he believed he owed, and because he believed that,
under such circumstances, he would not be penalized for failure
to timely file.” Ferguson v. Commissioner, supra. We rejected
those reasons as inadequate in Ferguson, and we reject them here.
As we stated in Ferguson: “These excuses are not adequate to
show reasonable cause for petitioner’s failure to file timely
returns for the years in issue.”6 Id.
In Knight v. Commissioner, T.C. Memo. 1984-376, the taxpayer
did not file returns for three years. In explaining that fail-
6According to petitioner, an important distinction between
Ferguson v. Commissioner, T.C. Memo. 1994-114, and the instant
case is that in Ferguson the taxpayer “never paid the necessary
taxes to the Government.” We reject that distinction as factu-
ally inaccurate. Petitioner has not paid all of the tax that he
owes for 1996, and he so conceded in the stipulations that he
entered into with respondent when he stipulated that he has an
underpayment for 1996 of $40,882.69.
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