- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
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