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v. Commissioner, 788 F.2d 1406, 1408 (9th Cir. 1986), affg.
T.C. Memo. 1984-533; Kennelly v. Commissioner, 56 T.C. 936, 943
(1971), affd. 29 AFTR 2d 72-855, 72-1 USTC par. 9348 (2d Cir.
1972).
Due to petitioner’s failure to request available
reimbursement for his employee business expenses, petitioner is
not entitled to deduct them. See Orvis v. Commissioner, supra at
1408; Kennelly v. Commissioner, supra at 943.
Petitioner is liable for the deficiencies in income tax
determined by respondent for the years in issue.
Petitioner’s argument that he failed to file Federal income
tax returns and to pay tax for the years in issue because of his
purported belief that wage and investment income does not
constitute taxable income is frivolous. Petitioner has offered
no credible evidence showing that his failure to file Federal
income tax returns and to pay estimated tax was due to reasonable
cause. We sustain respondent’s determination of the section
6651(a)(1) addition to tax and the section 6654(a) addition to
tax.
Under section 6651(a)(2), an addition to tax may be imposed
on a taxpayer for failure to pay any Federal income tax reflected
as due on a tax return. Petitioner failed to file Federal income
tax returns for the years in issue, and respondent has not
asserted that respondent prepared substitute tax returns for
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