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in issue is due to negligence or intentional disregard of rules
or regulations. Rule 142(a); Luman v. Commissioner, 79 T.C. 846,
860-861 (1982).
Based on the record, we find that petitioner's entire
underpayments for 1987 and 1988 are due to negligence and his
intentional disregard of the rules or regulations which require
him to report his income. Accordingly, we hold that petitioner
is liable for the section 6653(a)(1)(A) and (B) additions to tax
for 1987 and the section 6653(a)(1) addition to tax for 1988.
The fourth issue for decision is whether petitioner is
liable for the section 6654(a) additions to tax for failure to
make estimated income tax payments for 1987 and 1988.
Unless the taxpayer demonstrates that one of the statutory
exceptions applies, imposition of the section 6654(a) addition to
tax is mandatory where prepayments of tax, either through
withholding or by making estimated quarterly tax payments during
the course of the taxable year, do not equal the percentage of
total liability required under the statute. Sec. 6654(a);
Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).
Petitioner bears the burden of proving his entitlement to any
exception. Habersham-Bey v. Commissioner, 78 T.C. 304, 319-320
(1982).
The reporting payers withheld taxes from petitioner's income
sources in the amounts of $189 and $659 for 1987 and 1988,
respectively. Petitioner did not make any estimated tax payments
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