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not show reasonable cause when she was employed and running her
own business during the period in question).
It is undisputed that petitioner herein failed to file a
2000 Federal income tax return within the prescribed deadline.
Petitioner argues that he simply did not realize that disability
benefits were to be treated as taxable income.
Especially, however, after receiving the UCLI W-2 form
showing the disability benefits as taxable, petitioner did not
seek the advice of a professional and did not exercise ordinary
care and prudence as to the taxability of the disability
payments.
We conclude that neither petitioner’s lack of knowledge nor
his health problems constitute reasonable cause for his failure
to file his 2000 Federal income tax return. Petitioner is liable
for the section 6651(a)(1) addition to tax for failure to file a
return.
Section 6654(a) imposes an addition to tax on an
underpayment of estimated tax unless one of the statutory
exceptions applies. Niedringhaus v. Commissioner, 99 T.C. 202,
222 (1992). The enumerated exceptions provide that the addition
shall not be imposed: (1) If the tax is less than $1,000, or
(2) where there was no tax liability for the preceding taxable
year. Sec. 6654(e)(1) and (2). For the latter purpose, we look
to the tax liability shown on the return for the previous year,
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