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sustain Revenue Agent Dugger’s computation of petitioner’s
unreported income.
2. Additions to Tax
a. Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failing to
file timely a required Federal income tax return, unless it is
shown that the failure was due to reasonable cause and not
willful neglect. Petitioner was required to file Federal income
tax returns for each of the subject years. Secs. 6012, 6072.
Petitioner never asserted or presented any evidence
indicating that he filed one or more of the required returns.
Nor did he establish reasonable cause for his failure to do so.
Consequently, we hold that petitioner is liable for the addition
to tax under section 6651(a)(1). See United States v. Boyle, 469
U.S. 241, 245 (1985); Cluck v. Commissioner, 105 T.C. 324,
338-339 (1995).
b. Section 6654(a)
Section 6654 imposes an addition to tax on an underpayment
of estimated tax. This addition to tax is mandatory unless the
taxpayer establishes that one of the exceptions listed in section
6654(e) applies. Recklitis v. Commissioner, 91 T.C. 874, 913
(1988). Given that the record does not establish that any of the
referenced exceptions applies, we conclude that petitioner has
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