-40-
We have already sustained respondent's deficiency
determinations for the years 1989, 1993, and 1994. We have found
that petitioner is entitled to some additional business expense
deductions for 1990, 1991, and 1992. However, we have otherwise
sustained respondent's deficiency determinations, and have found
that petitioner still owed substantial amounts of tax, for each
of those years.
We have found that no payments or credits were made to
petitioner's income tax account for any of the years 1989-94,
prior to 1996. Therefore, we also find that no required
installments of estimated tax were paid for those years.
Petitioner neither argued nor offered evidence suggesting that
any of the statutory exceptions to the estimated tax additions
apply, or that respondent's determination of petitioner's
liability for those additions is in error.
Accordingly, we sustain respondent's determinations of the
additions to petitioner's tax under section 6654(a), for each of
the years 1989-94, except to the extent such determinations must
be adjusted to take account of the additional deductions we have
found for 1990-92.
To reflect all the foregoing,
An order will be issued
denying petitioner's motion in
limine, and decision will be
entered under Rule 155.
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