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burden of proving that the $20,169 deposit was not taxable
income. Petitioner testified that the $20,169 deposit was a
nontaxable transfer from another account. Petitioner’s testimony
was vague, and he offered no other evidence about the $20,169
bank deposit. We are not convinced that the deposit was not
income. We conclude that the $20,169 deposit was taxable income,
and that petitioner had unreported income of $17,430 in 1993,
$18,252 in 1994, $32,014 in 1995, $44,866 in 1996, and $24,650 in
1997.
C. Whether Petitioner Is Liable for the Addition to Tax for
Failure To File Returns
A taxpayer is liable for an addition to tax of up to 25
percent for failure to file a Federal income tax return unless
the failure was due to reasonable cause and not willful neglect.
Sec. 6651(a)(1).
Respondent determined that petitioner is liable for the
addition to tax under section 6651(a)(1) for failure to file
returns for the years in issue. Petitioner contends that he is
not liable because he had reasonable cause for not filing
returns. Petitioner points out that the names on some of the
Forms 1999, 1098, Mortgage and Interest Statement, and W-2 on
which his Social Security number appears include Otoole, O Toole,
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