Marilyn J. Baker - Page 11




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          taxpayer establishes that the failure was due to reasonable cause           
          and not willful neglect.  Sec. 6651(a)(1).  "Reasonable cause"              
          requires the taxpayer to demonstrate that he exercised ordinary             
          business care and prudence.  United States v. Boyle, 469 U.S.               
          241, 246 (1985).  Willful neglect is defined as a "conscious,               
          intentional failure or reckless indifference."  United States v.            
          Boyle, supra at 245.  Petitioner provided no evidence regarding             
          her failure to file her returns for 1994 and 1995.  Accordingly,            
          we sustain respondent’s determination on this issue.                        
               We now consider whether petitioner is liable for the                   
          additions to tax under section 6654(a) for underpayments of                 
          estimated taxes for 1994, 1995, and 1996.  Section 6654(c)                  
          imposes a requirement that estimated taxes be paid in                       
          installments.  If a taxpayer fails to pay a sufficient amount of            
          estimated taxes, section 6654(a) provides for a mandatory                   
          addition to tax in the absence of exceptions not applicable here.           
          Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).                      
          Petitioner is liable for the additions to tax under section 6654.           


                                             Decision will be entered                 
                                        for respondent.                               










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