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U.S. 241, 245 (1985). To prove reasonable cause, a taxpayer must
show that he or she exercised ordinary business care and prudence
but nevertheless could not file the return when it was due. See
Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-
1(c)(1), Proced. & Admin. Regs. Because petitioner failed to
present a reasonable explanation for his failure to file and
failed to allege any specific facts with respect to the addition
to tax, and because liability for the addition to tax was deemed
admitted pursuant to Rule 90, respondent's determination with
respect to the addition to tax under section 6651(a)(1) is
sustained.
Additionally, respondent determined an addition to tax under
section 6651(a)(2) for failure to pay tax. Section 6651(a)(2)
provides for an addition to tax of 0.5 percent per month up to
25 percent for failure to pay the amount shown on a return. This
addition to tax, however, applies only in the case where a return
has been filed. See Spurlock v. Commissioner, T.C. Memo. 2003-
124; see also Burr v. Commissioner, T.C. Memo. 2002-69, affd. 56
Fed. Appx. 150 (4th Cir. 2003); Heisey v. Commissioner, T.C.
Memo. 2002-41, affd. 59 Fed. Appx. 233 (9th Cir. 2003). Under
section 6651(g)(2), a return that the Secretary prepared under
section 6020(b) is treated as “the return filed by the taxpayer
for purposes of determining the amount of the addition” under
section 6651(a)(2). For these purposes, a section 6020(b)
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