Douglas G. Turnidge - Page 9

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          burden of production.  See, e.g., Spurlock v. Commissioner, T.C.            
          Memo. 2003-124.  Petitioner did not specifically address his                
          liability for the addition to tax, and the evidence in the record           
          lacks any indication that his failure to file was due to                    
          reasonable cause and not willful neglect.  Accordingly, we hold             
          that petitioner is liable for the addition to tax under section             
          6651(a)(1) for the years in issue.                                          

                                                  Decision will be entered            
                                            under Rule 155.                          






























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