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shown here) reasonable cause for his failure timely to pay the
tax shown on that return.
If petitioner had paid his 1999 liability upon being
notified in March 2005 as to how the proceeds of the 1999 check
had been applied, then we might be receptive to an argument that
the amount of the section 6651(a)(2) addition to tax should not
exceed the amount that accrued up until the date the 1999 check
was received. But he did not pay that tax when so notified, and
as best can be determined from the record, as of the date of
trial in this case, the tax shown on petitioner’s 1999 return
remained largely, if not entirely, unpaid. Consequently, more
than enough time has elapsed to allow for the imposition of the
maximum amount of penalty, as petitioner has not shown reasonable
cause for his continued failure to pay after March 2005.
Consequently, petitioner is liable for the entire amount of the
section 6651(a)(2) addition to tax for 1999.
In all other respects, we are satisfied that respondent
has complied with the provisions of section 6330 and petitioner
does not suggest otherwise. It follows that respondent’s
determination to proceed with collection of petitioner’s 1999 tax
liability in accordance with the Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330,
dated May 23, 2005, is sustained.
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