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See Turner v. Commissioner, T.C. Memo. 2004-251; sec. 1.151-1(b),
Income Tax Regs. Petitioner’s motion to reopen the record
states that his spouse receives Social Security income.
Accordingly, we hold that petitioner is not entitled to an
additional exemption under section 151. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
In his petition to this Court, petitioner claimed that he
had several deductible Schedule A expenses including church
donations, medical expenses, State and local taxes, and a
casualty loss. Petitioner has not presented any evidence
substantiating these expenses or showing that such expenses
totaled more than the standard deduction. At trial, petitioner
offered no testimony or other evidence concerning such expenses.
Accordingly, we hold that petitioner is not entitled to any
claimed Schedule A expenses. Rule 142(a); Welch v. Helvering,
supra.
Section 6651(a)(1) imposes an addition to tax for a failure
to file an income tax return. A taxpayer may be relieved of the
addition to tax, however, if he can demonstrate that the “failure
* * * [is] due to reasonable cause and not due to willful
neglect”. Higbee v. Commissioner, 116 T.C. at 446-447. Willful
neglect means intentional failure or reckless indifference.
United States v. Boyle, 469 U.S. 241, 245 (1985). Section
301.6651-1(c)(1), Proced. & Admin. Regs., provides that, if a
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