-9-
determination that petitioner is liable for self-employment tax.
See Rule 142(a).
D. Addition to Tax and Accuracy-Related Penalty
1. Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failing to
file timely a required Federal income tax return, unless it is
shown that the failure was due to reasonable cause and not to
willful neglect. Petitioner was required to file a Federal
income tax return for the subject year. Secs. 6012, 6072.
Respondent met his burden of production as to this addition
to tax in that respondent introduced (and the Court admitted)
into evidence documentation establishing that petitioner filed
his 1999 income tax return untimely. Petitioner, in turn, has
failed to meet his burden of proof. Petitioner has neither
asserted nor introduced any evidence indicating that he filed his
return untimely for cause that is reasonable. We hold that
petitioner is liable for the addition to tax under section
6651(a)(1). See United States v. Boyle, 469 U.S. 241, 245
(1985); Cluck v. Commissioner, 105 T.C. 324, 338-339 (1995).
2. Accuracy-Related Penalty
Section 6662(a) and (b)(1) imposes a penalty equal to 20
percent of the amount of an underpayment attributable to
negligence or disregard of rules or regulations. In this
context, negligence includes any failure to make a reasonable
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