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U.S. 241, 245 (1985).
Petitioner stipulated that he filed his 1992 return late and
that he did not file returns for 1993 and 1994. Petitioner
stated that he had no good excuse or compelling reason for not
filing.
Petitioner offered no evidence showing that his failure to
file timely was due to reasonable cause and not due to willful
neglect. Accordingly, we hold that petitioner is liable for the
addition to tax pursuant to section 6651(a)(1) for 1992, 1993,
and 1994.
III. Section 6654
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Petitioner must come forward with evidence
sufficient to persuade the Court that respondent’s determination
is incorrect or that an exception applies. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Petitioner did not offer any evidence at trial related to
this issue, and he failed to address it on brief. We conclude
that petitioner is liable for an addition to tax pursuant to
section 6654 for 1993 and 1994.
IV. Section 6662
Pursuant to section 6662(a), a taxpayer may be liable for a
penalty of 20 percent on the portion of an underpayment of tax
(1) attributable to a substantial understatement of tax or (2)
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