Michael J. Barkley - Page 19

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          return, we hold that he did not have reasonable cause for his               
          failure to file as required by section 6651(a)(1) and that,                 
          therefore, petitioner is liable for the addition to tax                     
          respondent determined.                                                      
               We have considered the remaining arguments of both parties             
          for results contrary to those expressed herein and, to the extent           
          not discussed above, find those arguments to be irrelevant, moot,           
          or without merit.                                                           
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          



























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