- 5 -
failure to file the return was due to reasonable cause and not
due to willful negligence. See Higbee v. Commissioner, 116 T.C.
438, 446 (2001). The addition to tax under section 6651(a)(1)
is, therefore, applicable, and respondent is sustained on that
determination.
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007