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Once respondent meets his burden of production, petitioner must
come forward with evidence sufficient to persuade the Court that
respondent’s determination is incorrect. Id.
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed (determined with regard to
any extension of time for filing), unless petitioner can
establish that his failure is due to reasonable cause and not due
to willful neglect. The parties stipulated and petitioner
testified that he did not file a Federal income tax return for
2000. We find that respondent has met his burden of production.
To show reasonable cause, petitioner must demonstrate that
he “exercised ordinary business care and prudence and was
nevertheless unable to file the return within the prescribed
time”. Sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Petitioner
argues that he had reasonable cause for failing to file because:
(1) The income tax system is “voluntary”; and (2) the self-
incrimination provision of the Fifth Amendment protects him from
being required to file a tax return.
Arguments relating to the “voluntary” nature of the income
tax system have been repeatedly rejected as frivolous or without
merit. See, e.g., Takaba v. Commissioner, 119 T.C. 285, 295-296
(2002); Rinn v. Commissioner, T.C. Memo. 2004-246; Hodge v.
Commissioner, T.C. Memo. 1998-242; Hicks v. Commissioner, T.C.
Memo. 1992-80. Furthermore, petitioner was previously informed
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