Stanley L. Wade - Page 13

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          was instructed by his income tax return preparer not to file any            
          Federal income tax returns during respondent’s criminal                     
          investigation of petitioners’ 1982 and 1983 returns.  Petitioner,           
          however, has offered no explanation for not filing his 1984                 
          income tax return immediately after the conclusion in 1990 of the           
          criminal tax proceedings against him.  We sustain respondent’s              
          determination of this addition to tax.                                      
               Finally, we sustain for 1984 respondent’s determination                
          under section 6654 of the addition to tax for the failure of                
          petitioner to pay estimated taxes.  Petitioner did underpay                 
          estimated taxes with regard to income earned in 1984, and                   
          petitioner does not meet any of the exceptions to the requirement           
          to pay estimated taxes.  Sec. 6654(d).                                      
               To reflect the foregoing,                                              

                                             Decisions will be entered                
                                        under Rule 155.                               


















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