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timely file unless he proves that his failure to timely file was
due to reasonable cause and not willful neglect. See United
States v. Boyle, supra.
Petitioner contends that he is not liable for the addition
to tax under section 6651(a)(1) for 1987-90 and 1992 because he
had reasonable cause for believing that NOLs carried forward from
1981-86 to the years in issue eliminated his obligation to file
returns for 1987-90 and 1992. We disagree. After carrying
forward NOLs from 1981-86 to the years in issue, petitioner
reported tax due of $65,838 for 1987, $53,434 for 1988, $25,139
for 1989, $29,602 for 1990, and $37,571 for 1992. Thus,
petitioner’s contention that he was not required to file returns
for 1987-90 and 1992 is inconsistent with those returns.
Petitioner contends that he was not required to file income
tax returns because the addition to tax under section 6651(a)
applies only to taxes related to alcohol, tobacco, and certain
firearms, but not to income tax. We disagree. The addition to
tax under section 6651(a) applies to late filing of income tax
returns. Sec. 6651(a).
Petitioner contends that he was not required to file income
tax returns because (a) he testified that he was not engaged in a
taxable activity, and (b) respondent did not cross-examine him on
this point or present any evidence to rebut his testimony. We
disagree. Petitioner admitted in his return filed for each year
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