Thomas G. Brenner - Page 16

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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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