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agreement pursuant to section 1.163-8T, Temporary Income Tax
Regs., 52 Fed. Reg. 24999 (July 2, 1987). We believe that the
proper allocation of petitioner's interest expense can be
mutually resolved and expect the parties to enter a stipulated
computation to that effect.
Respondent also determined that petitioner is liable for
additions to tax under section 6654(a) for failure to pay
estimated income tax. Section 6654(a) provides for an addition
to tax "in the case of any underpayment of estimated tax by an
individual". Subject to certain exceptions provided by
statute, this addition to tax is otherwise automatic if the
amounts of the withholdings and estimated tax payments do not
equal statutorily designated amounts. Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980).
Petitioner failed to produce any evidence that would tend
to show that any of the statutory exceptions should apply or
that respondent's determination of petitioner's liability for
the addition to tax under section 6654(a) is in error.
Consequently, because petitioner failed to make any estimated
tax payments during the years in issue, we hold that he is
liable for the additions to tax under section 6654(a) for 1992
and 1993.
An appropriate order will be
issued.
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