MEMORANDUM OPINION

THORNTON, Judge: Respondent determined the following deficiencies and additions to tax in petitioner's Federal income taxes: ¹

                   Additions to Tax

Year    Deficiency      Sec. 6651(a)(1)      Sec. 6654____    __________      _______________      _________

1996     $ 4,195         $ 1,009         $ 214

19972003 Tax Ct. Memo LEXIS 346">*347     4,377           993          210

1998     3,908           977          179

The issues for decision are: (1) Whether petitioner received unreported interest income as determined in the notices of deficiency, and (2) whether petitioner is liable for additions to tax pursuant to sections 6651(a)(1) and 6654 for the years at issue.

             Background

When he petitioned this Court, petitioner resided in Oklahoma City, Oklahoma.

For each year at issue, petitioner received interest income from numerous financial institutions. The interest income totaled $ 39,648, $ 36,859, and $ 32,683 for 1996, 1997, and 1998, respectively. ²

Petitioner filed no Federal income tax return for 1996 or 1997. On May 7, 1999, the Internal Revenue Service received from petitioner a Form 1040, U.S. Individual Income Tax Return,2003 Tax Ct. Memo LEXIS 346">*348 for his 1998 tax year. This document (the purported 1998 return) lists on Schedule E, Supplemental Income and Loss, $ 32,683 of "Royalties received & interest", offset by $ 81,556 of claimed expenses. On the 1998 purported return, petitioner lists no earned income but claims a "1997 loss carry over" of $ 407,246, a $ 3,783,344 earned income credit, and a refund of the same amount. In the jurat above his signature, petitioner scratched out the words "Under penalty of perjury." ³

2003 Tax Ct. Memo LEXIS 346">*349 With respect to each of petitioner's 1996, 1997, and 1998 tax years, respondent prepared a "substitute for return" (SFR). ⁴ On December 22, 2000, respondent issued notices of deficiency based on the SFRs. In the notices of deficiency, respondent determined that petitioner received unreported interest income in the following amounts, on the basis of information reports from financial institutions: ⁵

2003 Tax Ct. Memo LEXIS 346">*350         Year      Unreported Interest Income

        1996           $ 32,668

        1997            33,895

        1998            32,678

On June 2, 2003, this case was called for trial in Lubbock, Texas. Petitioner failed to appear, and no appearance was made on his behalf.

             Discussion

Although petitioner failed to appear at trial and to prosecute his case, respondent's counsel chose to proceed with trial. Accordingly, we regard this case as submitted by the parties. See Rule 149(a). ⁶

The evidence shows that petitioner received interest income in amounts at least as great as determined in the notices of deficiency. In fact, by his own admissions in his petition, petitioner received more interest income than was determined in the notices of deficiency. Respondent has not sought increased deficiencies based on these admissions. Therefore, we sustain respondent's deficiency determinations. ⁷

B. 2003 Tax Ct. Memo LEXIS 346">*352 Additions to Tax

1. Failure To File Timely Returns

For each year at issue, respondent determined that petitioner is liable for the section 6651(a)(1) addition to tax for failing to file a timely Federal income tax return. Section 6651(a)(1) imposes an addition to tax for failing to file a tax return on or before the specified filing date unless the taxpayer establishes that the failure "is due to reasonable cause and not due to willful neglect". Sec. 6651(a)(1); see United States v. Boyle, 469 U.S. 241">469 U.S. 241, 469 U.S. 241">245, 83 L. Ed. 2d 622">83 L. Ed. 2d 622, 105 S. Ct. 687">105 S. Ct. 687 (1985).

Respondent offered into evidence Form 3050, Certificate of Lack of Record, which indicates that no income tax return for petitioner is on file with the Internal Revenue Service for any year at issue. In his petition, petitioner alleges that he filed a Federal income tax return for each year at issue. On each of these purported returns, petitioner crossed out the words "Under penalty of perjury" from the jurat above his signature. For this reason, if for no other, the purported returns do not constitute valid returns. See, e.g., Cupp v. Commissioner, 65 T.C. 68">65 T.C. 68, 65 T.C. 68">7879 (1975), affd. without published opinion 559 F.2d 1207">559 F.2d 1207 (3d Cir. 1977);2003 Tax Ct. Memo LEXIS 346">*353 Sochia v. Commissioner, T.C. Memo. 1998-294; see also Williams v. Commissioner, 114 T.C. 136">114 T.C. 136, 114 T.C. 136">140 (2000); Jenkins v. Commissioner, T.C. Memo. 1989-618; Jenkins v. Commissioner, T.C. Memo. 1989-617.

Petitioner has not shown that his failure to file valid returns was due to reasonable cause. To the contrary, his purported returns convince us that his failure to file valid returns resulted from his deliberate attempt to subvert the tax laws. Accordingly, we sustain respondent's determination of section 6651(a)(1) additions to tax as set forth in the notices of deficiency.

2. Failure To Pay Estimated Tax

For each year at issue, respondent determined that petitioner is liable for the section 6654 addition to tax for underpaying required installments of individual estimated tax.

In his petition, the only argument that petitioner raises that arguably pertains to the section 6654 addition to tax is that "Since there is no additional income, it follows that the additional claims for penalties are also in error." Contrary to petitioner's argument, however, we have sustained respondent's deficiency determinations as to the amount of petitioner's2003 Tax Ct. Memo LEXIS 346">*354 unreported income for each year at issue. Petitioner does not allege, and the evidence does not suggest, that any exception in section 6654(e) applies. ⁸ Accordingly, we sustain respondent's determination of section 6654 additions to tax as set forth in the notices of deficiency.

In reaching our holding, we have considered all arguments that petitioner raised in his petition. Arguments not addressed herein are irrelevant or without merit. ⁹

2003 Tax Ct. Memo LEXIS 346">*355 To reflect the foregoing,

Decision will be entered for respondent.