Charles Teslovich - Page 5

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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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