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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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