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that the failure to file did not result from willful neglect and
was due to reasonable cause. See United States v. Boyle, 469
U.S. 241, 245 (1985). To prove reasonable cause, a taxpayer must
show that he or she exercised ordinary business care and prudence
but nevertheless could not file the return when it was due. See
Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec. 301.6651-
1(c)(1), Proced. & Admin. Regs. Because petitioner failed to
present a reasonable explanation for his failure to file, nor any
genuine issue for trial in that regard, summary judgment is also
appropriate to sustain respondent's determination with respect to
the additions to tax under section 6651(a)(1).
Additionally, respondent determined additions to tax under
section 6651(a)(2) for failure to pay tax. Section 6651(a)(2)
provides for an addition to tax of 0.5 percent per month up to
25 percent for failure to pay the amount shown on a return. This
addition to tax, however, applies only in the case where a return
has been filed. See Spurlock v. Commissioner, T.C. Memo. 2003-
124; see also Burr v. Commissioner, T.C. Memo. 2002-69; Heisey v.
Commissioner, T.C. Memo. 2002-41, affd. 59 Fed. Appx. 233 (9th
Cir. 2003). Under section 6651(g)(2), a return the Secretary
prepared under section 6020(b) is treated as “the return filed by
the taxpayer for purposes of determining the amount of the
addition” under section 6651(a)(2). For these purposes, a
section 6020(b) return, in the context of section 6651(a)(2) and
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