Daniel V. Presnick - Page 7

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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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