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evidence or argument in explanation or mitigation. Accordingly,
we hold him liable for additions to tax under section 6651(a)(1).
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. When there has been a failure to pay
estimated tax, the addition under section 6654 is mandatory and
no inquiry is made as to possible reasonable cause or lack of
willful neglect. Grimes v. Commissioner, 82 T.C. 235, 237
(1984). Petitioner also has the burden of proving that he is not
liable for this addition to tax. Rule 142(a); Habersham-Bey v.
Commissioner, 78 T.C. 304, 319-320 (1982). Petitioner has failed
to explain why he should not be held liable for the addition.
Accordingly, we hold him liable for the addition to tax under
section 6654 for the years in issue.
To reflect the foregoing and respondent's concession,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011