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to file his 1995 and 1996 income tax returns but has presented no
evidence as to why he should not be liable for the addition to
tax for failure to file. Petitioner has also failed to show that
his failure to pay was due to reasonable cause. Cf. Estate of
La Meres v. Commissioner, 98 T.C. 294, 324-326 (1992).
Accordingly, we sustain the determinations of respondent with
respect to the section 6651(a)(1) and (2) additions to tax,
taking into account respondent’s concession regarding the section
6651(a)(2) determination for the 1995 tax year.
B. Additions to Tax Under Section 6654
Section 6654 requires the imposition of an addition to tax
in the case of any underpayment of estimated tax by an
individual. See Estate of Ruben v. Commissioner, 33 T.C. 1071,
1072 (1960). This addition to tax is mandatory absent a showing
by the taxpayer that one of the statutorily provided exceptions
applies. See Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner introduced no evidence as to the
applicability of any such exceptions, and, accordingly, we
sustain respondent’s determinations with respect to section 6654.
We have considered all other arguments advanced by the
parties, and to the extent that we have not addressed these
arguments, we consider them irrelevant, moot, or without merit.
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