- 9 - file a Federal income tax return. The evidence in this record persuades us that there was no reasonable cause for the failure to file. Therefore, we conclude that petitioner is liable for the addition to tax as claimed by respondent in the answer. Section 6654(a) imposes an addition to tax for failure to pay estimated tax. The addition to tax is mandatory and does not contain a provision relating to reasonable cause or willful neglect. Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992); Recklitis v. Commissioner, 91 T.C. 874, 913 (1988). Petitioner did not pay an estimated tax despite the receipt of substantial amounts of commission income. We conclude that petitioner is liable for the addition to tax as asserted by respondent in the answer. Accordingly, we conclude that petitioner is liable for the increased deficiency and increased additions to tax for the taxable year 1993 asserted by respondent in the answer. Penalty Under Section 6673 Petitioner is the same person who filed a petition in docket No. 20340-94 in response to a notice of deficiency issued for the taxable years 1991 and 1992.2 In that case the Commissioner determined and asserted, among other adjustments, that petitioner received commission income from Matol, which payments were 2 A notice of deficiency for the taxable years 1991 and 1992 was also issued to petitioner's wife, Kathleen Harvey. She filed a petition at docket No. 20339-94, and that docket was ultimately consolidated with docket No. 20340-94.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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