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amended petition that accompanied his motion failed to identify
any specific deductions or credits to which petitioner would be
entitled.
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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