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(1982). Nothing in the record suggests that petitioner applied
for an extension of time to file his 1994 return. Petitioner did
not show that as of the due date of his 1994 return he did not
have information showing the amount of his income for 1994. Nor
did he establish that he could not have prepared a timely 1994
return with a reasonable degree of accuracy based on the informa-
tion available to him as of the due date of that return. On the
record before us, we find that petitioner has not demonstrated
that the failure to file timely his 1994 return was due to
reasonable cause, and not to willful neglect. We further find on
that record that petitioner is liable for 1994 for the addition
to tax under section 6651(a)(1).
Section 6654(a) imposes an addition to tax in the case of
any underpayment of estimated tax by an individual. The addition
to tax under section 6654(a) is mandatory unless petitioner
qualifies under one of the exceptions in section 6654(e). See
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Peti-
tioner claims that he made estimated tax payments with respect to
the income that he expected to earn for 1994 and that one of the
reasons why he did not make the appropriate amount of estimated
tax payments for that year related to certain unresolved tax
issues for 1993 that were pending before the Internal Revenue
Service. Petitioner does not argue, and did not prove, that he
qualifies under any of the exceptions listed in section 6654(e).
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