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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.
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