Betty June Dykstra and Pieter Dykstra - Page 11

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          argument is without merit.  For 1995, petitioners argue that they           
          were unable to file a return because they were notified that they           
          were under audit and were in the midst of the appeal process.  We           
          do not believe that these circumstances demonstrate reasonable              
          cause for failure to file a return.  We conclude that petitioners           
          are liable for the additions to tax pursuant to section                     
          6651(a)(1) for 1994 and 1995.                                               
          Failure To Pay Estimated Income Tax                                         
               Respondent determined that petitioners were liable for an              
          addition to tax for their failure to pay estimated Federal income           
          tax under section 6654(a) in 1995.  This addition to tax is                 
          mandatory in the absence of a showing by petitioners that a                 
          statutory exception applies.  See Grosshandler v. Commissioner,             
          75 T.C. 1, 20-21 (1980).  Petitioners failed to present any                 
          evidence demonstrating that a statutory exception applies in this           
          case.  Accordingly, we sustain respondent's determination.                  
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          

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