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ure, the taxpayer contended at trial that “his reasons for
failing to file involved an unconfirmed belief that he did not
owe any tax, the ‘trauma’ of all his problems and the fact that,
unless someone was pressuring him to do something, he did not do
it.” Id. We held that those reasons did not constitute reason-
able cause for failure to file the returns in question within the
meaning of section 6651(a)(1). See id. We find the explanations
offered by petitioner here for his failure to file timely his
1996 return and his failure to pay timely his 1996 tax liability
to be similar to the excuses offered by the taxpayer in Knight.
We rejected those excuses in Knight, and we reject those explana-
tions here.
On the record before us, we find that petitioner’s failure
to file timely his return for 1996 and his failure to pay timely
his tax liability for that year were not due to reasonable cause
but were due to willful neglect.
On the record before us, we find that petitioner is liable
for the additions to tax under section 6651(a)(1) and (2).
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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