Jorge Zamora-Quezada - Page 4

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          unpersuaded by this claim.  It is clear that the Federal income tax         
          reaches income that is earned in the United States by an alien even         
          if deemed a nonresident.  See secs. 61, 872, 7701(b); see also              
          secs. 861(a)(1) and (3), 864(b).                                            
               Respondent also determined an addition to tax under section            
          6654 for each year in issue, asserting that petitioner failed to            
          pay estimated tax.  This addition to tax is mandatory unless                
          petitioner proves he met one of the exceptions contained in section         
          6654.  Recklitis v. Commissioner, 91 T.C. 874, 913 (1988).                  
          Petitioner has failed to do so.  Accordingly, we sustain                    
          respondent's determinations under section 6654.                             
               To reflect the foregoing,                                              
                                             Decision will be entered for             

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