Don H. Wisden - Page 14

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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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