Randolph John Beale - Page 23




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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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