- 20 - 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 respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
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