- 13 - discussed above, the filing by another of a Form W-2 does not satisfy the requirements for filing an individual income tax return. See Manka v. United States, supra; Koeneman v. Commissioner, supra. Respondent is sustained on this issue. 3. Section 6654(a) Estimated Taxes Respondent determined that petitioner is liable for additions to tax under section 6654(a) for failure to pay estimated income tax for 1989, 1990, and 1991. Where payments of tax, either through withholding or by making estimated quarterly tax payments during the course of the year, do not equal the percentage of total liability required under the statute, imposition of the addition to tax under section 6654 is applicable, unless petitioner shows that one of the statutory exceptions applies. Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner bears the burden to show qualification for such exception. Habersham-Bey v. Commissioner, 78 T.C. 304, 319- 320 (1982). The parties stipulated that for each of the taxable years at issue, with the exception of 1990, Federal income tax was not withheld from the wages attributed to petitioner herein. During 1990, Hackney's withheld Federal income tax in the amount of $16 on wages of $1,104 and Esrock withheld Federal income tax in the amount of $48 on wages of $13,433. There is no showing in the record that petitioner made estimated tax payments for any of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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