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record, we further find that petitioner has failed to carry his
burden of showing that his failure to file a tax return for each
of those years was due to reasonable cause and not due to willful
neglect. On the record before us, we find that petitioner has
failed to establish that he is not liable for each of the years
at issue for an addition to tax under section 6651(a)(1).2
With respect to respondent’s respective determinations for
the years at issue of additions to tax under section 6654(a),
respondent points out that in the petition petitioner did not
assign any error to those determinations. According to respon-
dent, pursuant to Rule 34(b)(4), each issue not addressed in the
petition by a clear and concise assignment of error, including
additions to tax and penalties, is deemed to have been conceded.
We agree with respondent. See Funk v. Commissioner, 123 T.C.
213, 215 (2004); Swain v. Commissioner, 118 T.C. 358, 363 (2002).
In the petition, petitioner failed to assign error to the addi-
tions to tax under section 6654(a) that respondent determined in
the respective notices for the years at issue. On the record
before us, we find that petitioner is deemed to have conceded
such additions to tax. Petitioner failed to place at issue in
2The calculation of the amount of the addition to tax under
sec. 6651(a)(1) for each of the years at issue for which we have
held petitioner is liable is not subject to sec. 6651(c)(1).
That is because respondent conceded the addition to tax under
sec. 6651(a)(2) that respondent determined for each of those
years.
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