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229; Surowka v. United States, 909 F.2d 148 (6th Cir. 1990);
Miller v. United States, 784 F.2d 728, 730 (6th Cir. 1986); Brown
v. Commissioner, T.C. Memo. 1997-567, affd. without published
opinion 181 F.3d 99 (6th Cir. 1999); Bruder v. Commissioner, T.C.
Memo. 1989-328. We are not required to accept, nor shall we
accept, petitioner’s testimony that he timely mailed his return.
See Geiger v. Commissioner, 440 F.2d 688, 689 (9th Cir. 1971),
affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). Nor do we attach any weight to the
dubious copy of petitioner’s return for 2000 that he produced at
trial.
Moreover, petitioner makes no argument that he had
reasonable cause and lacked willful neglect in not filing the
return. In fact, he claims he did file the return. We therefore
find that petitioner has failed to demonstrate reasonable cause
and lack of willful neglect. Accordingly, we sustain
respondent’s determination that petitioner is liable for the
addition to tax under section 6651(a)(1) for failure to file
timely. Because respondent did not submit a computation to the
Court reflecting the proposed increase, we sustain respondent
only as to the addition to tax under section 6651(a)(1)
determined in the notice of deficiency.
Respondent also determined petitioner was liable for an
addition to tax of $268 under section 6654(a) for failure to make
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