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Petitioner presented nothing to show that he filed timely his
1994 return, nor did he raise as an issue any claim or contention
that the tampered or altered Forms 1040 he submitted for 1994
constituted a valid return for that year. Respondent, therefore,
is sustained on the section 6651(a)(1) addition to tax.
The third issue is whether petitioner is liable for the
addition to tax under section 6654 for his failure to make
estimated tax payments in 1994. Section 6654 provides for an
addition to tax "in the case of any underpayment of estimated tax
by an individual". There is no exception contained therein
relating to reasonable cause and lack of willful neglect.
Subject to certain exceptions provided by statute, this addition
to tax is otherwise automatic if the amounts of the withholdings
and estimated tax payments do not equal statutorily designated
amounts. Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).
Petitioner failed to produce any evidence to show that
respondent's determination of his liability for the addition to
tax under section 6654 is in error. Consequently, because
petitioner failed to make any estimated tax payments for 1994,
respondent's determination in this regard is sustained.
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
On a final note, section 6673(a)(1) authorizes this Court to
require a taxpayer to pay a penalty to the United States, in an
amount not to exceed $25,000, whenever it appears that
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