Fred Willie Thomas, Jr. - Page 11

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          cause and not due to willful neglect.  Accordingly, we sustain              
          respondent's determination that he is liable for additions to tax           
          under section 6651(a)(1).                                                   
          3.  Additions to Tax Under Section 6654                                     
               Respondent determined an addition to tax under section 6654            
          for each year in issue, asserting that petitioner failed to pay             
          estimated tax.  This addition to tax is mandatory unless                    
          petitioner proves that he has met one of the exceptions contained           
          in section 6654.  In re Sanford, 979 F.2d at 1514; Recklitis v.             
          Commissioner, 91 T.C. 874, 913 (1988).  Because petitioner has              
          failed to do so, we sustain respondent on this issue.                       
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          























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