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return for 1996 and offered no evidence showing that his failure
to file was due to reasonable cause and not due to willful
neglect. Accordingly, we hold that petitioner is liable for the
addition to tax under section 6651(a)(1).
B. Section 6651(a)(2): Failure To Pay
Respondent also determined that petitioner is liable for an
addition to tax pursuant to section 6651(a)(2) for 1996.
Petitioner presented no evidence or argument that the
addition was improper. Additionally, petitioner did not present
evidence indicating that his failure to pay was due to reasonable
cause and not due to willful neglect. Accordingly, on this
issue, we sustain respondent’s determination.
C. Section 6654(a): Failure To Pay Estimated Tax
Respondent determined that petitioner is liable for an
addition to tax pursuant to section 6654(a) for 1996. Section
6654(a) imposes an addition to tax for failure to pay estimated
income tax. Petitioner did not offer any evidence at trial
related to this issue and failed to address it on brief.
Therefore, we sustain respondent’s determination on this issue.
III. Section 6673(a)(1) Penalty
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not to exceed
$25,000 if the taxpayer took frivolous positions in the
proceedings or instituted the proceedings primarily for delay. A
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