-11-
We are not persuaded that petitioner acted in good faith or
in fact relied on Long when he prepared his 1040 document. We
find that petitioner’s asserted reliance on Long does not
constitute reasonable cause and the absence of willful neglect.
In sum, petitioner has not shown that his failure to file a
Federal income tax return for 2001 was due to reasonable cause
and not to willful neglect. Thus, we find that petitioner is
liable for the addition to tax under section 6651(a)(1).
Petitioner has argued that he should not be subject to the
addition to tax under section 6651(a)(1) because the addition to
tax penalizes him for asking for an explanation why he was liable
to file a return and pay tax. Petitioner’s arguments were
frivolous. Although petitioner filed returns and paid tax for 20
years previously and respondent notified petitioner in 2000 that
his arguments were frivolous, petitioner nevertheless attempted
to challenge the tax system by filing documents reporting zero
income and zero tax liability and attaching frivolous tax
protester correspondence. Petitioner was well aware of the
requirement to file tax returns and pay tax, but petitioner
continued to assert shopworn, meritless tax protester arguments.
We have imposed a penalty under section 6673 on taxpayers who
have raised similar arguments. See, e.g., Roberts v.
Commissioner, 118 T.C. 365 (2002), affd. per curiam 329 F.3d 1224
(11th Cir. 2003); Pierson v. Commissioner, 115 T.C. 576 (2000);
Hodges v. Commissioner, T.C. Memo. 2005-168. Though we do not
impose a penalty here, nor does respondent seek a section 6673
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