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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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Last modified: May 25, 2011