Cathy Miller Hardy - Page 21

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          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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