- 43 - Petitioner bears the burden of proving error in respondent’s determination pursuant to section 6661(a). Weis v. Commissioner, 94 T.C. 473, 490 (1990). Petitioner presented no argument concerning his liability for the addition to tax provided by section 6661(a). The understatement of petitioner’s income tax for 1987 was substantial. On the record before us, we hold that petitioner failed to carry his burden of proof with respect to respondent’s determination pursuant to section 6661(a). Section 6654(a) Addition to Tax Respondent also determined that, for 1988 and 1989, petitioner is liable for the addition to tax provided by section 6654(a) for failure to pay estimated income tax. Imposition of that addition to tax is mandatory where prepayments 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 by the statute, unless petitioner shows that one of the several statutorily provided exceptions applies. Sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C. at 222; Grosshandler v. Commissioner, 75 T.C. at 20-21. For 1988 and 1989, petitioner filed no returns and made no estimated tax payments. Petitioner has not shown that any of the statutorily provided exceptions apply to him. We therefore sustain respondent’s determination of petitioner’s liability for the addition to tax for failure to pay estimated income tax for those years.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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