James O. Reuben - Page 4




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          suffered no detriment that is legally recognizable.  He is only             
          required to pay the tax that was lawfully owing.  He did not                
          change a position to his detriment.                                         
               With regard to the late filing addition to tax, section                
          6651(a)(1) provides for an addition to tax where a return is not            
          timely filed “unless it is shown that such failure is due to                
          reasonable cause and not due to willful neglect”.  Petitioner               
          acknowledges that his return was not timely filed.  He claims               
          that he had “so many things going on” that he forgot.  This does            
          not constitute reasonable cause.                                            


                                                  Decision will be entered            
                                             for respondent.                          

























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Last modified: May 25, 2011