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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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Last modified: May 25, 2011