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failure to file is due to reasonable cause if the taxpayer
exercised ordinary business care and prudence and, nevertheless,
was unable to file the return within the prescribed time.
Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-
1(c)(1), Proced. & Admin. Regs. Willful neglect means a
conscious, intentional failure to file or reckless indifference
to the obligation to file. United States v. Boyle, supra.
Petitioner has stipulated that he did not file a Federal
income tax return for the year in issue. Thus respondent has
satisfied his burden of production with respect to the addition
to tax for failure to file a timely return. Higbee v.
Commissioner, supra; Burr v. Commissioner, T.C. Memo. 2002-69.
Petitioner has failed to show that his failure to file was due to
reasonable cause and not due to willful neglect. Accordingly, we
sustain respondent’s determination on this issue.
Section 6654 imposes an addition to tax in the case of any
underpayment of estimated tax by an individual.3 The addition to
tax under section 6654(a) is mandatory in the absence of
statutory exceptions. Sec. 6654(a), (e); Recklitis v.
Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). With limited exceptions
that are inapplicable here, section 6654 “has no provision
3We have jurisdiction over the sec. 6654(a) addition to tax
in this case because an income tax return was not filed for the
year at issue. See sec. 6665(b)(2); Meyer v. Commissioner, 97
T.C. 555, 562 (1991); Heisey v. Commissioner, T.C. Memo. 2002-41.
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