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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 the
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