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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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