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ordinary business care and prudence. If petitioner was
uncertain about the status of his oldest daughter as a
dependent, he could have attached a statement to each
return disclosing his uncertainty. We find that petitioner
has not established reasonable cause for his failure to
file his 1992, 1993, and 1994 income tax returns.
Accordingly, we sustain respondent's determination of the
addition to tax under section 6651(a)(1).
Respondent determined an addition to tax for failure
to pay estimated income tax under section 6654 for 1992,
1993, and 1994. Section 6654(a) provides for an addition
to tax "in the case of any underpayment of estimated tax by
an individual" unless one of the exceptions contained in
that section is applicable. See generally Niedringhaus
v. Commissioner, 99 T.C. 202, 222 (1992). Petitioner's
position amounts to a naked assertion that he is not liable
for the addition to tax under section 6654. He has
presented no evidence that any of the exceptions set forth
therein applies, nor has he presented any other basis to
find that respondent's determination is wrong. Accord-
ingly, we sustain respondent's determination and find
petitioner liable under section 6654 for his failure to
make estimated tax payments for 1992, 1993, and 1994.
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