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116 T.C. 438, 446 (2001). On the record presented in this case,
respondent has carried the requisite burden of production with
respect to the additions to tax under sections 6651(a)(1) and
6654.
Section 6651(a)(1) imposes an addition to tax for failure to
file a required return on or before the prescribed filing date,
unless it is shown that such failure is due to reasonable cause
and not due to willful neglect. “Willful neglect” denotes “a
conscious, intentional failure or reckless indifference.” United
States v. Boyle, 469 U.S. 241, 245 (1985). “Reasonable cause”
correlates to “ordinary business care and prudence”. Id. at 246
& n.4; sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
Through the testimony of the revenue agent, along with
transcripts and other documents admitted as evidence, respondent
showed that petitioner was required to file a return for each of
the subject years and failed to do so. Petitioner has offered no
legitimate explanation for this failure. The Court holds that
petitioner is liable for additions to tax under section 6651 for
1999, 2000, and 2001.
Section 6654 imposes an addition to tax for underpayment of
estimated tax, subject to limited exceptions enumerated in
subsection (e). The record here reflects an underpayment of
estimated tax for each year in issue, and we do not find that any
of the referenced exceptions is applicable. Imposition of an
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