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We discussed at length whether petitioner in fact filed a
return for 1986 in our previous opinion regarding respondent's
motion for partial summary judgment, Joseph v. Commissioner, T.C.
Memo. 1996-77. We concluded that petitioner did not file a
return for 1986, and our discussion does not merit repetition
here.
Accordingly, respondent's addition to tax under section
6651(a) is sustained.2
Addition to Tax Under Section 6654
Respondent determined an addition to tax under section 6654
for underpayment of individual estimated tax. Petitioner asserts
that he is not liable for this addition to tax. Petitioner
failed to pay his estimated tax. Accordingly, in light of the
foregoing, we sustain the addition to tax.3
For the foregoing reasons,
Decision will be entered
under Rule 155.
2
This addition, however, must be recomputed taking into
account petitioner's allowable business deductions.
3
This addition, however, must be recomputed taking into
account petitioner's allowable business deductions.
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Last modified: May 25, 2011