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Because petitioner did not file income tax returns for the
years in issue, petitioner’s tax liabilities for those years
constitute deficiencies in income taxes. See sec. 6211(a).3
In view of the foregoing, we hold that petitioner is liable
for the deficiencies in income taxes as determined by respondent
in the notices of deficiency.
C. Additions to Tax For Failure To File
As applicable to petitioner, section 6012(a)(1)(A)(i)
requires that an income tax return be filed by every individual
who has gross income equal to, or greater than, the sum of the
standard deduction and one personal exemption. For an individual
who is a calendar-year taxpayer, the return is due on or before
the 15th day of April following the close of the taxable year.
See sec. 6072(a).
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return. The addition to tax may be avoided if the
failure to file is due to reasonable cause and not willful
neglect. “Reasonable cause” contemplates that the taxpayer
exercised ordinary business care and prudence and was nonetheless
3 As acknowledged by respondent, petitioner’s net tax
liabilities for the years in issue are as follows:
1995 1996 1997
Tax liability $7,852 $15,917 $12,210
Less: Withholding
By the Railroad -412 -4,677 ---
By Belle/Sioux City --- -250 ---
Net tax liability 7,440 10,990 12,210
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Last modified: May 25, 2011