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the tax due within the date prescribed by law, then reasonable
cause exists. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
“Willful neglect” means a “conscious, intentional failure or
reckless indifference.” United States v. Boyle, supra at 245.
Petitioner’s 1999 Federal income tax return was due on April
15, 2000. As previously stated, on April 6, 2004, after the
notice of deficiency was issued, petitioner submitted a Form 1040
for the taxable year 1999 to respondent’s Appeals officer.
Petitioner testified that he had no real explanation for not
filing his 1999 return on time. Petitioner did not pay the
balance shown on his return when he submitted it to respondent’s
Appeals officer. Respondent has carried his burden of producing
evidence to show the additions to tax are appropriate.
Petitioner has failed to show that he exercised ordinary business
care and prudence in this case. Respondent’s determinations are
sustained.
b. Section 6654(a)
Respondent also determined that petitioner is liable for an
addition to tax for the underpayment of estimated tax pursuant to
section 6654(a).
Section 6654(a) provides that in the case of an underpayment
of estimated tax by an individual, there shall be added to the
tax an amount determined by applying the underpayment rate
established under section 6621 to the amount of the underpayment
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