- 12 -
(1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Thus, in the present case, we need not address any issue relating
to reasonable cause and lack of willful neglect; extenuating
circumstances are simply irrelevant.5 See Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960); see also Grosshandler v.
Commissioner, supra at 21.
In the present case, petitioner failed to pay estimated tax
for any of the years in issue. Moreover, only a negligible
portion of petitioner’s tax liability for 1995 was paid through
withholding; only a relatively small portion of petitioner’s tax
liability for 1996 was paid through withholding; and none of
petitioner’s tax liability for 1997 was paid through withholding.
In view of the foregoing, we hold that petitioner is liable
for the additions to tax under section 6654 as determined by
respondent in the notices of deficiency.
F. Jurisdiction Over the Crediting of Alleged Overpayments
As we understand his argument, petitioner contends that his
Federal tax refunds for 1987 through 1994 were intercepted and
applied against child support obligations for 1983 through 1988
that he did not owe.6 Because, in petitioner’s view, his refunds
5 We should not be understood to imply that petitioner had
reasonable cause or that there were any extenuating circumstances
relating to petitioner’s failure to pay estimated tax.
6 Factually, the record does not fully support petitioner’s
contention.
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