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estimated tax payments. This addition to tax is mandatory and
cannot be waived due to reasonable cause. Grosshandler v.
Commissioner, 75 T.C. 1, 21 (1980); sec. 1.6654-1(a), Income Tax
Regs. However, no addition to tax is imposed under section
6654(a) if one of the exceptions set forth in section 6654(e) is
satisfied. Under section 6654(e)(2), no addition to tax is
imposed under section 6654(a) if: (1) The taxpayer's preceding
taxable year was a taxable year of 12 months; (2) the taxpayer
did not have any tax liability for the preceding taxable year;
and (3) the taxpayer was a citizen or resident of the United
States throughout the preceding taxable year. Pursuant to our
finding above that petitioner's MARC fellowship was excludable
from income during 1989, petitioner had no tax liability and was
not required to file a tax return for that year. In addition,
petitioner was a resident of the United States throughout 1989.
Consequently, petitioner has satisfied the exception under
section 6654(e)(2) for his 1990 taxable year. We hold that
petitioner is not liable for the addition to tax under section
6654(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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