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The documents petitioner submitted for tax years 1999 and
2000 are not recognized by respondent as returns because they do
not constitute Forms 1040 and they fail to provide any
information required by Form 1040, specifically the amount of
petitioner's income for each year.
None of the documents submitted by petitioner constitute
returns. Therefore, petitioner has yet to file any returns.
Petitioner has not offered any evidence that his failure to file
is due to reasonable cause and not to willful neglect.
Respondent's determinations that petitioner is liable for the
additions to tax under section 6651(a)(1) are sustained.
Respondent also determined an addition to tax under section
6654 for petitioner's underpayment of estimated tax for 1999 and
2000. This addition to tax is mandatory and automatic, subject
to certain exceptions provided by section 6654(e). Grosshandler
v. Commissioner, 75 T.C. 1 (1980). Petitioner failed to offer
any evidence that he fits within any of the listed exceptions.
Respondent's determinations that petitioner is liable for section
6654 additions to tax are sustained.
Petitioner did not introduce any evidence to show that he is
not liable for the income tax deficiencies and additions to tax
under sections 6651(a)(1) and 6654; accordingly, respondent's
determinations for all 4 years are sustained.
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Last modified: May 25, 2011