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tax protester argument that wastes the Court’s time and
resources.
We do not address petitioner’s argument with somber
reasoning and copious citations of precedent, as to do so might
suggest that petitioner’s arguments possess some degree of
colorable merit. See Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984). Accordingly, we hold that petitioner is liable
for the amounts of the deficiencies in his income tax set forth
in the notices of deficiency for taxable years 1997 and 2002.
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
additions to tax, however, if he can demonstrate that the failure
is “due to reasonable cause and not to willful neglect”. Higbee
v. Commissioner, supra at 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 taxpayer exercises ordinary business
care and prudence and is nevertheless unable to file on time,
then the delay is due to reasonable cause. Petitioner did not
timely file tax returns during the years in issue because he does
not believe that there is a Code section requiring him to pay
income tax. Misguided interpretations of the Constitution or
other typical tax protester arguments are not reasonable cause.
See Yoder v. Commissioner, T.C. Memo. 1990-116. Accordingly, we
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