Frederick C. Kumpel - Page 15

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          required to be deposited if the failure to deposit is more than             
          15 days late.  A taxpayer may avoid the addition to tax by                  
          showing that the failure to deposit was due to reasonable cause             
          and not due to willful neglect.  Sec. 6656(a); Charlotte’s Office           
          Boutique v. Commissioner, supra at ___ (slip op. at 31).                    
               Petitioner asserts that he “refused to use” an employer                
          identification number and acknowledges the obligations of an                
          employer that he deliberately tried to avoid.  Petitioner’s                 
          position is essentially that he did not want to incur the                   
          obligations of an employer and therefore did not comply with the            
          applicable law.  Petitioner is liable for the additions to tax              
          under section 6651 and section 6656.                                        
               We have considered all arguments made by the parties.  Those           
          arguments not discussed are irrelevant or without merit.  To                
          reflect the foregoing,                                                      
                                                  Decision will be entered            

                                             for respondent.                          

















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