Robert Conrad Eanes II - Page 9




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          has no provision relating to reasonable cause and lack of willful           
          neglect.  It is mandatory and extenuating circumstances are                 
          irrelevant.”)  None of the statutory exceptions under section               
          6654(e) applies in this case.                                               
               Respondent determined that petitioner is liable for an                 
          addition to tax under section 6654 for each tax year at issue.              
          He subsequently conceded, however, that petitioner is not liable            
          for the addition to tax under section 6654 for 1994 and 1996.               
          Petitioner conceded at trial that he did not make any payments of           
          estimated tax.  Since petitioner was required to make estimated             
          tax payments for all of the years at issue except 1994 and 1996             
          and he failed to do so, respondent’s determination as modified is           
          sustained.                                                                  
               To reflect the foregoing and the concessions of the parties,           


                                                  Decision will be entered            
                                             under Rule 155.                          


















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