- 10 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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