- 18 - Under section 6651(a)(1), a taxpayer who fails to file a Federal income tax return by the date due may be liable for an addition to tax unless the taxpayer demonstrates reasonable cause and not willful neglect. Generally, a taxpayer who is required to pay but who significantly underpays estimated Federal income taxes shall be liable for an addition to tax. Sec. 6654(a). Petitioner admits that he had no reasonable cause for his failure to file Federal income tax returns for the years in issue. We sustain respondent’s determination of section 6651(a)(1) failure to file additions to tax and section 6654 estimated tax additions to tax against petitioner for 1999, 2000, 2001, and 2002. We have considered all arguments made herein, and, to the extent not addressed, we conclude that they are without merit or are irrelevant. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18Last modified: March 27, 2008