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tax equal to 5 percent per month of the underpayment up to a
maximum of 25 percent for untimely filed returns. This addition
to tax is not imposed if there was reasonable cause for the
failure to file. We hold that petitioner has not shown that
there was reasonable cause for his failure to file a 1994 return
and, therefore, he is liable for the addition to tax, which will
be recomputed under Rule 155.
4. Addition to Tax for Failure to Make Estimated Income Tax
Payments Petitioner failed to make estimated income tax payments
in 1994. However petitioner did not earn income in 1993 and did
not have any income tax liability for 1993. Respondent agreed
that if petitioner did not have any income tax liability for
1993, the exemption under section 6654(e)(2) would apply and
petitioner would not be liable for this addition to tax.
Accordingly, we hold that petitioner is not liable for the
addition to tax under section 6654(a).
5. Tax Protester Arguments
The bulk of this case--the bulk of the pleadings,
stipulation of facts, supplemental stipulation of facts, and
petitioner’s testimony relates to petitioner’s version of why he
is not liable for income tax under the Internal Revenue Code. We
will not list petitioner’s misguided arguments or attempt to
refute them with copious citations, for to do so would grant them
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