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by making estimated quarterly tax payments during the course of
the taxable year, do not equal the percentage of total liability
required under the statute. Sec. 6654(a); Niedringhaus v.
Commissioner, supra at 222; Grosshandler v. Commissioner, 75 T.C.
1, 20-21 (1980). Petitioner bears the burden of proving his
entitlement to any exception. Habersham-Bey v. Commissioner, 78
T.C. 304, 319-320 (1982).
Respondent's determination takes into account a small amount
of withholding for 1993. Petitioner did not make any estimated
tax payments for 1991, 1992, or 1993, nor has he shown that any
of the statutory exceptions are applicable in this case. We
therefore sustain respondent's determination on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011