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by this Court that he is required to file Federal income tax
returns and was found liable for additions to tax under section
6651(a)(1) for failure to file. See Keenan v. Commissioner, T.C.
Memo. 1998-388 (“Petitioner was required to file Federal income
tax returns * * * He failed to do so and offered no satisfactory
explanation.”). Therefore, we find petitioner’s argument that
the income tax system is “voluntary” cannot serve as a reasonable
basis for his failure to file.
Petitioner’s belief that the Fifth Amendment’s self-
incrimination provision protected him from filing a tax return is
not a reasonable basis for failure to file under section 6651(a).
See Woods v. Commissioner, 91 T.C. 88, 91-92 (1988); Thompson v.
Commissioner, 78 T.C. 558, 563 (1982). Petitioner testified that
he is not currently under criminal investigation. Nevertheless,
petitioner believes the Fifth Amendment protects him because
there is always the potential that he may be subject to a
criminal investigation at a later date. We find that
petitioner’s belief cannot serve as a reasonable basis for
failure to file. We hold that petitioner is liable for the
addition to tax under section 6651(a)(1).
Section 6654(a) imposes an addition to tax on an
underpayment of estimated tax unless one of the statutory
exceptions applies. Respondent’s Certificate of Official Record
indicates that petitioner did not make estimated tax payments in
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