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Section 6654 imposes an addition to tax for failure to make
estimated tax payments. Petitioner did not remit estimated tax
payments for the years in issue. In addition, she has failed to
establish that she falls within any of the exceptions to section
6654. Therefore, petitioner is liable for the section 6654
additions to tax.
All other arguments raised by the parties are either moot or
without merit.
To reflect the foregoing,
Decision will be entered
pursuant to Rule 155.
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Last modified: May 25, 2011