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neglect. To the contrary, his asserted reasons for refusing to
file returns are patently frivolous. Consequently, we sustain
respondent's determination that petitioner is liable for the
additions to tax under section 6651(a)(1) for the years 1991
through 1994.
4. Section 6654 Failure To Pay Estimated Tax
For each year in issue respondent determined that petitioner
is liable for the additions to tax under section 6654 for his
failure to make estimated tax payments. Where payments of tax,
either through withholding or by making estimated quarterly tax
payments during the course of the year, do not equal the amount
required under the statute, imposition of the addition to tax
under section 6654 is automatic, unless the taxpayer shows that
one of the statutory exceptions applies. Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner bears the
burden to show qualification for such exception. Habersham-Bey
v. Commissioner, 78 T.C. 304, 319-320 (1982). The record does
not show that he qualifies for any exception; therefore, we hold
that he is liable for the additions to tax under section 6654 for
the 1991 through 1994 taxable years.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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