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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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Last modified: May 25, 2011