Darel Guy Taken, Jr. - Page 12




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          willful neglect.  “Reasonable cause” contemplates that the                  
          taxpayer exercised ordinary business care and prudence in                   
          providing for payment of the taxpayer’s tax liability and was               
          nonetheless unable to pay the tax or would suffer an undue                  
          hardship if the tax were paid within the prescribed time.  Sec.             
          301.6651-1(c)(1), Proced. & Admin. Regs.  “Willful neglect” means           
          a conscious, intentional failure or reckless indifference.                  
          United States v. Boyle, supra at 245.                                       
               In the present case, petitioner paid only a relatively small           
          portion of his tax liability for 1996 and failed to pay any of              
          his tax liability for 1997.  Petitioner offered no evidence                 
          whatsoever that would support a finding that his failure to pay             
          was due to reasonable cause and not willful neglect.                        
               In view of the foregoing, we hold that petitioner is liable            
          for the additions to tax under section 6651(a)(2) as determined             
          by respondent in the notices of deficiency.                                 
          E.  Additions to Tax for Failure To Pay Estimated Tax                       
               Section 6654 imposes an addition to tax for failure to pay             
          estimated tax.  As applicable herein, imposition of the addition            
          is mandatory whenever prepayments of tax, either through                    
          withholding or the making of estimated quarterly tax payments               
          during the course of the taxable year, do not equal the                     
          percentage of total liability required under the statute.  See              
          sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C. 202, 222                






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