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increased amount of unreported income for all years in question
is sustained. See Hardy v. Commissioner, 181 F.3d 1002, 1005
(9th Cir. 1999), affg. T.C. Memo. 1997-97.
C. Additions to Tax
Section 6651(a)(1) imposes an addition to tax for failing to
timely file a required Federal income tax return, unless it is
shown that the failure was due to reasonable cause and not
willful neglect. Petitioner was required to file Federal income
tax returns for each of the subject years because his income
exceeded the maximum amount to be exempt from filing in each of
the taxable years. Secs. 6012, 6072.
As was the situation in petitioner’s prior case, respondent
offered Forms 4340, Certificate of Assessments, Payments and
Other Specified Matters, and the testimony of a revenue agent as
proof that petitioner failed to file returns for the subject
years. Once again, petitioner failed to introduce any evidence
indicating that he filed the returns or that his failure to file
was reasonable. Accordingly, we again hold that petitioner is
liable for the additions to tax under section 6651(a)(1). United
States v. Boyle, 469 U.S. 241, 245 (1985); Cluck v. Commissioner,
105 T.C. 324, 338-339 (1995).
Section 6654 imposes an addition to tax on an underpayment
of estimated tax. Again, Forms 4340 and the testimony of the
revenue agent establish that petitioner failed to pay the
required estimated tax for 1997, 1999, and 2000. Furthermore, no
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