Jack F. and Virginia Surridge - Page 15

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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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