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III. Section 6654
Respondent determined that petitioners underpaid their
estimated income tax and are liable for additions to tax under
section 6654. Where payments of tax, either through withholding
or by making estimated tax payments, do not equal the percentage
of the total liability required under the statute, imposition of
the addition to tax under section 6654 is automatic, absent a
showing that the taxpayer has met one of the exceptions contained
therein. Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Tillman v. Commissioner, T.C. Memo. 1996-8. Petitioners have not
shown that any of the exceptions apply. We sustain respondent's
determination on this issue.
We have considered all of petitioners' arguments in this
case, and, to the extent not discussed above, find them to be
irrelevant or without merit. To reflect the foregoing,
Decisions will be entered
under Rule 155.
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