CHARLES EDWIN LYKES - Page 10

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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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