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face value. See, e.g., Day v. Commissioner, 975 F.2d 534, 538
(8th Cir. 1992), affg. in part, revg. in part T.C. Memo. 1991-
140; Liddy v. Commissioner, 808 F.2d 312, 315 (4th Cir. 1986),
affg. T.C. Memo. 1985-107.
Petitioner has failed to prove facts to contradict
respondent’s determination of an addition to tax in the amount of
$5,916.25 under section 6651(a). Therefore, we sustain
respondent's determination of an addition to tax under section
6651(a)(1), subject only to recalculation of the deficiency.
D. Addition to Tax for Failure To Pay Estimated Tax
Section 6654(a) provides for an addition to tax in the case
of any underpayment of estimated tax by an individual. In the
notice of deficiency, respondent determined an addition to tax
under that section in the amount of $1,029.42. In the petition,
petitioner assigns error to that determination but avers no facts
in support of that assignment. We must decide whether petitioner
is liable for the section 6654(a) addition to tax as determined
by respondent (the estimated tax issue).
As a preliminary matter, we must decide whether we have
jurisdiction to decide the estimated tax issue. Generally, we
have jurisdiction to redetermine additions to tax under the
deficiency procedures. Estate of DiRezza v. Commissioner,
78 T.C. 19, 25-26 (1982). An addition to tax under section
6654(a), however, is subject to the deficiency procedures, and we
have jurisdiction to redetermine such an addition to tax, only if
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