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any extension of time for filing), unless it is shown that such
failure is due to a reasonable cause and not due to willful
neglect. Sec. 6651(a)(1). The taxpayer has the burden of
proving the addition is improper. Rule 142(a); United States v.
Boyle, 469 U.S. 241, 245 (1985).
Petitioner did not file income tax returns for the years in
issue. There is no evidence in the record that suggests
petitioner's failure to file a Federal income tax return for any
year in issue was due to reasonable cause and not due to willful
neglect. Accordingly, we sustain respondent's determination with
respect to this issue.
Issue 5. Additions to Tax Under Section 6654
Respondent determined that petitioner is liable for the
addition to tax under section 6654(a) for his failure to make
estimated tax payments for 1991, 1992, and 1993.
Subject to exceptions provided by the statute, the
imposition of the addition to tax is otherwise automatic if the
amounts of the withholdings and estimated tax payments do not
equal statutorily designated amounts. Niedringhaus v.
Commissioner, supra at 222; Grosshandler v. Commissioner, 75 T.C.
1, 20-21 (1980). Petitioner bears the burden of showing that
respondent's determination that section 6654 applies to all 3
taxable years is in error. Rule 142(a); Niedringhaus v.
Commissioner, supra. Petitioner has made no such showing. For
the years in issue petitioner had substantial taxable income, yet
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