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$70,000. However, petitioner admits that he did not disclose the
fact that he had wage income from Varian in 1990, which was
earned in the United States. In light of this fact, it would not
have been reasonable for petitioner to rely on the advice
received at the U.S. consulate. Marprowear Profit-Sharing Trust
v. Commissioner, 74 T.C. 1086 (1980), affd. without published
opinion 673 F.2d 1300 (3d Cir. 1981).
On this record, we cannot conclude that petitioner, a
college-educated individual who had filed returns for the
previous 2 years, undertook a reasonable and sufficient inquiry
as to his obligation to file in 1990. Given that he earned
significant wage income in the United States during 1990, which
was subject to withholding, and resided in the United States for
over 10 months of that year, we do not believe that petitioner
had a reasonable basis for concluding that no income tax return
was due. Therefore, because petitioner has failed to establish
reasonable cause for his failure to timely file his 1990 return,
he is liable for the addition to tax under section 6651(a)(1).
Failure To Pay Estimated Tax
Respondent also determined an addition to tax for failure to
pay estimated income tax under section 6654(a). The addition to
tax under section 6654(a) is mandatory unless petitioner can show
that he comes within one of the exceptions of section 6654(e).
Hudson v. Commissioner, 103 T.C. 90, 110 (1994), affd. without
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