Hugh Powell Arvin - Page 8

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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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