- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011