- 21 -
least a portion of the income that was paid to him during those
years to pay at least some of the living expenses. Petitioner
also worked during the years at issue. However, petitioner did
not at anytime make an attempt to determine whether she was
required to file a return for any of those years.
On the record before us, we find that petitioner's failure
to file returns for the years at issue was not due to reasonable
cause. Accordingly, we sustain respondent's determinations, as
reduced on brief by respondent, imposing the addition to tax
under section 6651(a)(1) for each of those years.20
Section 6654(a)
Respondent determined that petitioner is liable for each of
the years at issue for the addition to tax under section 6654(a)
because she failed to pay estimated taxes for each such year.
The addition to tax under section 6654(a) is mandatory unless the
taxpayer establishes that one of the exceptions under section
6654(e) applies. Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner does not claim, and the record does not
support a finding, that any of the exceptions under section
6654(e) applies.
On the record before us, we sustain respondent's determina-
20 Although not altogether clear, there may be a disagreement
between the parties about the amounts of the prepayment credits
for the years at issue to which petitioner is entitled in comput-
ing the additions to tax under sec. 6651(a), as well as sec.
6654(a). We direct the parties to resolve any such disagreement
in their computations under Rule 155.
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