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Issue 6. Failure To Pay Estimated Income Tax
Respondent determined that petitioner was liable for the
addition to tax under section 6654(a) for failure to pay
estimated tax for the years in issue. 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 petitioner shows 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). None of the exceptions applies. We therefore sustain
respondent on this issue.
Decision will be entered
under Rule 155.
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