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Commissioner, supra. We sustain respondent's determination of
additions to tax for negligence for all of the years in issue.
Respondent determined an addition to tax against petitioner
under section 6654(a) for failure to make timely estimated tax
payments. This addition to tax generally is mandatory and cannot
be waived due to reasonable cause. See Recklitis v.
Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 21 (1980); Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960); sec. 1.6654-1(a), Income
Tax Regs. However, no addition to tax is imposed under section
6654(a) if one of the exceptions set forth in section 6654(e) is
satisfied. Petitioner presented no evidence that an exception
applies and failed to address this issue on brief. We sustain
respondent's determination of the addition to tax under section
6654 for all years in issue.
We have considered all arguments made by petitioner, and, to
the extent not addressed above, find them to be without merit.
To reflect the foregoing,
An appropriate order
will be issued and decision
will be entered for respondent
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