Cliff Connors - Page 22

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          amended petition that accompanied his motion failed to identify             
          any specific deductions or credits to which petitioner would be             
               Mrs. Connors testified that petitioner had three children,             
          one of whom was in China with him.  Her testimony is insufficient           
          to show that petitioner was entitled to a dependency exemption              
          for any of his children under sections 151 and 152, to the child            
          tax credit under section 24, or to any other credits for 2002.              
          Neither at trial nor in the offer of proof did petitioner present           
          sufficient information concerning custody of his children or                
          respective contributions to their support.  Additionally,                   
          although Mrs. Connors testified that she did not work in 2002,              
          her testimony, as well as petitioner’s failure to provide any               
          information as to her support, is insufficient to show that                 
          petitioner would be entitled to a dependency exemption for her.             
          Additions to Tax                                                            
               Respondent determined an addition to tax under section                 
          6651(a)(1) for the year in issue.  Section 6651(a)(1) provides              
          for an addition to tax of 5 percent of the tax required to be               
          shown on the return for each month or fraction thereof for which            
          there is a failure to file, not to exceed 25 percent.  The                  
          addition to tax for failure to file is not imposed if it is shown           
          that the failure to file did not result from willful neglect and            
          was due to reasonable cause.  See United States v. Boyle, 469               

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