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practiced law in Florida for over 47 years. It is well settled
that reasonable reliance on the advice of an attorney may
constitute reasonable cause for failure to file a timely return.
United States v. Boyle, supra at 250; Estate of La Meres v.
Commissioner, 98 T.C. 294, 314 (1992). We find that Faye's
reliance on her attorney's advice provided her with reasonable
cause for her failure to file income tax returns for the years in
issue. As a result, we hold that Faye is not liable for the
additions to tax under section 6651(a).
Respondent also determined that Faye is liable for an
addition to tax for failure to pay estimated tax under section
6654(a) for each of the years in issue. Unless one of the
statutory exemptions applies, imposition of this 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 under the statute. Sec. 6654(a); Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). This section has no
exception for reasonable cause and lack of willful neglect.
Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960);
Kramer v. Commissioner, T.C. Memo. 1996-513. Faye has not
demonstrated that any of the statutory exemptions apply. Thus,
we sustain respondent's determination.
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