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tax for failure to file. The Court has received into evidence
copies of petitioner’s tax returns for 1996 and 1997 stamped as
received by the Internal Revenue Service Center in Kansas City,
Missouri, on May 28, 1999, approximately 2 years and 1 year
delinquent, respectively. Respondent has sustained his burden of
production to show that the section 6651(a)(1) addition to tax is
appropriate. See Higbee v. Commissioner, 116 T.C. 438, 447
(2001).
If petitioner establishes that the failure to file timely
returns was due to reasonable cause and not due to willful
neglect, he can avoid the addition to tax. Sec. 6651(a)(1).
Petitioner 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 additions
to tax under section 6651(a).
IV. Penalties
A. Section 6662
Respondent determined that petitioner is liable for
accuracy-related penalties under section 6662(a) and (b)(1) for
1996, 1997, and 2000. Section 6662(a) imposes a penalty in the
amount of 20 percent on the portion of the underpayment to which
the section applies. As relevant to these cases, the penalty
applies to any portion of the underpayment that is attributable
to negligence or disregard of rules or regulations. Sec.
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