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is due to reasonable cause and not due to willful neglect.
United States v. Boyle, 469 U.S. 241, 243 (1985). Section
6651(a) imposes an addition to tax equal to 5 percent of
the tax required to be shown as tax on the return for every
month, or fraction thereof, that the return is late (not
to exceed 25 percent in the aggregate). Sec. 6651(a)(1).
Petitioner is deemed to have admitted that she did
"not file federal income tax returns for taxable years 1992
and 1993." She is also deemed to have admitted "liability
for the additions to tax under I.R.C. �� [sic] 6651(a) as
determined in the notice of deficiency." Accordingly, we
sustain respondent's determination as to the additions to
tax under section 6651(a)(1). For 1992, the amount of the
addition is $9,071, the amount determined in the notice
of deficiency. For 1993, the amount of the addition is
$9,360, the amount set forth in respondent's recomputation.
The final issue for decision is whether petitioner
is liable for the additions to tax for failure to pay
estimated income tax under section 6654(a) for 1993.
Section 6654(a) imposes an addition to tax equal to the
amount of the underpayment multiplied by the underpayment
rate established under section 6621 for the period of the
underpayment. Respondent recomputed an addition to tax
under section 6654(a) of $1,553. The addition to tax under
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