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sustained. Nothing in the above-cited language supports the
netting of expenses against gross income to determine whether or
not income tax returns were required to be filed for the years in
question.
Petitioner was required to file income tax returns for 1993
and 1994. He has failed to show that the failure to file was due
to reasonable cause and was not due to willful neglect.
Petitioner, therefore, is liable for the failure-to-file addition
to tax under section 6651(a). Therefore, respondent's
determination on this issue is sustained.
5. Sec. 6654(a) Addition to tax for Failure to pay Estimated tax
Respondent determined the addition to tax under section
6654(a) for failure to make estimated tax payments for 1993.
Section 6654(a) provides for an addition to tax "in the case of
any underpayment of estimated tax by an individual". There is no
exception contained therein relating to reasonable cause and lack
of willful neglect. Subject to certain exceptions provided by
statute and not pertinent here, this addition to tax is otherwise
automatic if the amounts of the withholdings and estimated tax
payments do not equal statutorily designated amounts. See
Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).
Petitioner produced no evidence to show that respondent's
determination of his liability for the addition to tax under
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