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burden of proving that his failure to file was due to reasonable
cause and not willful neglect. See United States v. Boyle,
supra.
Petitioner did not offer evidence showing that he had
reasonable cause for not filing his 1995 return. We conclude
that petitioner is liable for the addition to tax under section
6651(a)(1) for failure to file his 1995 income tax return.
C. Whether Petitioner Is Liable for the Addition to Tax for
Failure To Pay Estimated Tax
Respondent determined that petitioner is liable for the
addition to tax under section 6654 for failure to pay estimated
tax for 1995. We have jurisdiction to review this determination
because petitioner did not file a return for 1995. Sec.
6665(b)(2); Meyer v. Commissioner, 97 T.C. 555, 562 (1991).
To be liable for the addition to tax under section 6654, a
taxpayer must have underpaid or failed to pay estimated tax for
the year in issue. Sec. 6654(a). A taxpayer is liable for the
addition to tax for failure to pay estimated tax unless the
taxpayer shows that he or she meets one of the exceptions
provided in section 6654(e), none of which apply here.
Brown reviewed respondent’s administrative file in this
case, and testified that petitioner made no tax payments for
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