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Section 6651(a) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes: (1) The
failure did not result from willful neglect; and (2) the failure
was due to reasonable cause. See United States v. Boyle, 469
U.S. 241, 245-246 (1985). Petitioners bear the burden of proof
on this issue. See Rule 142(a); Baldwin v. Commissioner, 84 T.C.
859, 870 (1985). Petitioners failed to prove reasonable cause
for their failure to file. Accordingly, the addition to tax for
failure to file returns under section 6651(a) is sustained.
Issue 4. Failure To Pay Estimated Income Tax
Respondent determined that petitioners were liable for the
addition to tax under section 6654(a) for failure to pay
estimated tax for 1992, 1993, 1994, and 1995. Where payments of
tax, either through withholding or by making estimated quarterly
tax payments during the course of the year, do not equal the
percentage of total liability required under the statute,
imposition of the addition to tax under section 6654(a) is
automatic, unless petitioners show that one of the statutory
exceptions applies. See Niedringhaus v. Commissioner, 99 T.C.
202, 222 (1992); Habersham-Bey v. Commissioner, 78 T.C. 304, 319-
320 (1982); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioners have provided no evidence at trial or
argument on brief that any of these exceptions apply. We
therefore sustain respondent on this issue.
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