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6651(a) for failure to file and under section 6654 for failure to
pay estimated tax for 1998.
2. Failure To File Under Section 6651(a)(1)
A taxpayer is liable for an addition to tax of up to 25
percent for failure to file a Federal income tax return unless
the failure was due to reasonable cause and not willful neglect.
Sec. 6651(a)(1); United States v. Boyle, 469 U.S. 241, 245
(1985).
Petitioner contends that the statement he and his wife
submitted to the IRS satisfies his obligation to file a return or
other statement under the Code. We disagree. Petitioner’s
statement was not made in accordance with the forms and
regulations prescribed by the Secretary as required by section
6011(a) and did not include the dollar amounts or any other
information needed to determine tax liability. See Beard v.
Commissioner, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th
Cir. 1986).
Petitioner was well aware of his responsibility to file
returns as evidenced by his timely filing of returns for 1979
through 1997. His claim that the filing of an income tax return
is voluntary is frivolous. Petitioner wrote to the IRS stating
his belief that filing a return is voluntary and purporting to
give the IRS 30 days to refute his conclusion or he would proceed
accordingly. Petitioner’s claim that the IRS is collaterally
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