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shown that such a failure is due to reasonable cause and not due
to willful neglect. Petitioner bears the burden of proving that
his failure to file a timely return was due to reasonable cause
and not due to willful neglect. Rule 142(a); Baldwin v.
Commissioner, 84 T.C. 859, 870 (1985). Petitioner, however, did
not dispute his liability for these additions to tax. As a
result, petitioner has failed to carry his burden of proof and is
liable for the additions to tax for 1988 and 1989. Petitioner is
not liable, however, for the additions to tax with respect to
1990, 1991, and 1992, because we have concluded that there are no
deficiencies for those years.
IV. Additions to Tax for Failure To Make Estimated Tax Payments
Respondent determined that petitioner, pursuant to section
6654, was liable for additions to tax for failure to make
estimated tax payments. Section 6654 imposes an addition to tax
for failure to make estimated income tax payments. Petitioner
bears the burden of proving that he paid estimated tax or that
any of the exceptions apply. Rule 142(a); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner, however, did
not dispute his liability for these additions to tax. Therefore,
petitioner has failed to carry his burden of proof and is liable
for the additions to tax for 1988 and 1989. Petitioner is not
liable, however, for the additions to tax with respect to 1990,
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