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return was due to reasonable cause and not willful neglect. Rule
142(a); Baldwin v. Commissioner, 84 T.C. 859, 870 (1985).
Petitioner, however, did not dispute his liability for this
addition to tax. As a result, petitioner has failed to carry his
burden of proof and is liable for the addition to tax.
III. Addition to Tax for Failure To Make Estimated Tax Payments
Section 6654 imposes an addition to tax for failure to make
estimated income tax payments. Petitioner bears the burden of
proving that he paid estimated tax or that an exception applies.
Rule 142(a); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner, however, did not dispute his liability for
this addition to tax. As a result, petitioner has failed to
carry his burden of proof and is liable for the addition to tax.
We have considered the other arguments made by petitioner
and respondent and found them to be either irrelevant or without
merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011