Mark R. Halcott - Page 8

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          of willful neglect.  As a result, we hold that petitioner is                
          liable for the addition to tax under section 6651(a)(1) for                 
          failure to file a timely tax return for the year in issue.                  
               In reaching our holding herein, we have considered all                 
          arguments made, and, to the extent not mentioned above, we                  
          conclude that they are moot, irrelevant, or without merit.                  
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered for respondent.             

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