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Because respondent conceded that petitioner had no tax
liability for the year 1988, it follows that petitioner is not
liable for the addition to tax under section 6654 for the year
1989. Sec. 6654(e)(2). Although petitioner did not make any
estimated tax payments during any of the years in issue, it
appears that some of petitioner's employers withheld Federal
income taxes from the wages paid to him. Whether the conditions
necessary for the imposition of the addition to tax exist with
respect to the other years, and if so whether any exception
applies, can only be determined after the Rule 155 computations
have been submitted.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011