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years when her returns did not bear the signature of a
professional preparer. The provisions of Section 6651
cannot even apply to Petitioner because Petitioner did,
in fact, file her returns, and Respondent has offered
no proof to the contrary, nor can it. If the burden of
proof rests with Petitioner, there is a standoff, and
the case should be dismissed.
We find petitioner’s contentions and arguments under section
6651(a)(1) to be baseless, without merit, and/or irrelevant. On
the record before us, we find that petitioner has not shown that
her failure to file tax returns for her taxable years 1989
through 1992 was due to reasonable cause, and not to willful
neglect. Consequently, we sustain respondent’s determinations
that petitioner is liable for additions to tax under section
6651(a)(1) for those years.
Addition to Tax for Failure to Pay Estimated Tax
Section 6654(a) imposes an addition to tax for failure to
pay estimated tax. The addition to tax under section 6654(a) is
mandatory unless the taxpayer establishes that one of the excep-
tions in section 6654(e) applies. See Grosshandler v. Commis-
sioner, 75 T.C. 1, 20-21 (1980).
Petitioner contends that she is not liable for the additions
to tax under section 6654(a) for the years 1990 through 1992. In
support of that contention, petitioner argues:
in 1990, Petitioner prepaid over 100% of the estimated
taxes owed in 1989; thus, no further estimated payments
were required and no penalty was due therefor in 1990.
In 1991, no tax was due; thus, no estimated tax payment
was required in 1992. No estimated taxes were required
to be paid from 1989 through 1993. Exceptions to the
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