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Commissioner, 16 T.C. 893, 906 (1951). We are satisfied that
petitioner suffered physical injuries as a result of the car
accident, but she failed to show that they were sufficiently
debilitating to establish reasonable cause. See Carter v.
Commissioner, T.C. Memo. 1998-243, affd. in part 187 F.3d 640
(8th Cir. 1999). This conclusion is based on the fact that
petitioner, in 1996, continued her employment, remitted estimated
tax payments, and filed a request for an extension of time to
file her 1996 return. The ability to continue performing daily
business operations negates reasonable cause. See Dickerson v.
Commissioner, T.C. Memo. 1990-577; Fambrough v. Commissioner,
T.C. Memo. 1990-104. Respondent is sustained on this issue.
2. Addition to Tax Under Section 6654(a) for Failure To Pay
Estimated Tax
Section 6654(a) provides for an addition to tax “in the case
of any underpayment of estimated tax by an individual”. This
addition to tax is mandatory unless petitioner establishes that
one of the statutorily provided exceptions in section 6654(e)
applies. See Spurlock v. Commissioner, T.C. Memo. 2003-248 n.9.
But see Mackey v. Commissioner, T.C. Memo. 2004-70. Petitioner
underpaid estimated tax for 1996 and has not shown that any of
the statutory exceptions are applicable. Respondent is sustained
on this issue.
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