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delinquency was due to disability or other reasonable
cause.
* * * * * * *
Petitioner’s argument that his service during
Desert Storm during 1990 and 1991 somehow affected his
ability to comply with internal revenue laws almost six
years later is implausible, and not supported by any
evidence in the record. Petitioner abandoned that
argument upon questioning by the court.
Respondent’s position in this regard is well taken. The
Court further notes that petitioner did not provide Appeals
Officer Reagan or this Court with any financial records that
might have supported petitioner’s claim of undue hardship. We
may infer that petitioner had no records that would have
supported his claim.
We have carefully considered the reasons offered by
petitioner for his failure to timely file his 1996-99 tax returns
and timely pay the amounts shown on the returns for such years
when filed belatedly. Neither reason offered by petitioner
constitutes “reasonable cause”.
As to the section 6654 addition to tax for failure to pay
estimated taxes for 1996 and 1997, none of the statutory
exceptions apply. See sec. 6654(e). Consequently, the
imposition of this addition to tax is mandatory.
In sum, we conclude that respondent’s denial of petitioner’s
request for abatement of the additions to tax under section
6651(a)(1) and (2) and section 6654 was not an abuse of
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