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accorded him the single filing status and single exemption to
which he would be entitled in the absence of any further
information or substantiation. Given the proximity of the
notices of deficiency and the filing of respondent’s answer in
this case, we see no impropriety in respondent’s maintaining the
same position in his answer as in the notices. The record does
not indicate when petitioner’s 1995 and 1996 returns, submitted
after issuance of the notices of deficiency, were accepted as
filed, except that it is clear the returns had been accepted at
least 15 days prior to trial, when trial memoranda were served.
Whether respondent unreasonably delayed accepting the 1995 and
1996 returns in some effort to intimidate petitioner has not been
established on this record. We therefore find no basis for
petitioner’s claims of improper conduct by respondent.
Additions to Tax Under Section 6651(a)(1) and (2)
Respondent determined for the years in issue that petitioner
is liable for additions to tax under section 6651(a)(1) for
failure to file timely tax returns and under section 6651(a)(2)
for failure to pay timely. The addition to tax for failure to
file a timely return equals 5 percent of the amount required to
be shown as tax on the return for each month, or fraction
thereof, during which the failure to file continues, up to a
maximum of 25 percent. Sec. 6651(a)(1). For these purposes, the
amount required to be shown as tax on the return is reduced by
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