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that the late filing was due to reasonable cause. Accordingly,
she has not established that the addition should not apply. The
determination of respondent is sustained.
Section 6654(a) imposes an addition to tax if the total tax
withheld, or the estimated tax payments made during the year, do
not equal the percentage of liability required under the statute
to be paid as estimated tax, subject to limited exceptions. Sec.
6654. Petitioner offered no testimony or evidence that an
exception applies. Accordingly, respondent's determination is
sustained.
To reflect the foregoing,
Decision will be entered
for respondent.3
3 Although respondent conceded that petitioner is entitled to
automobile expense in the amount of $827.94, a Rule 155
computation is unnecessary because this amount does not exceed
the standard deduction used by respondent in determining the
amount of the deficiency.
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Last modified: May 25, 2011